De-Mystifying the Compliance Manual
In the past few years, HRSA has transitioned its compliance efforts from requiring FQHCS to utilize multiple guidance documents to ensure adherence to health center program requirements to issuing the Health Center Program Compliance Manual (the Manual), a consolidated resource to assist FQHCs in understanding, demonstrating, and operationalizing compliance.
The Manual, which supersedes most (but not all) prior guidance, incorporates a new approach to everyday compliance by addressing:
- Each requirement’s statutory and regulatory basis
- Key elements of compliance that form the framework of every health center’s project
- Documentation necessary for verification of compliance
- Areas where health centers maintain discretion
To assist in evaluating compliance, HRSA has also issued a Site Visit Protocol (the SVP), which aligns with the Manual and reflects a more objective assessment tool. Both the Manual and the Protocol are currently being used by HRSA for on-site reviews of grantees and FQHC look-alike entities (Operational Site Visits - OSVs) as well as for desk audits of project and designation renewal applications.
Is your health center prepared for the recent changes to compliance with HRSA requirements and the compliance assessment processes – both on-site and through the grant application? Have you reviewed the newest HRSA guidance with an eye towards shoring up your own operations and, as necessary, establishing your HRSA compliance work-plan? Specifically,
- Do you have HRSA-compliant written agreements in place for in-scope services provided by contract and/or formal referral?
- Are your providers appropriately credentialed and privileged and does your quality improvement system meet all current standards?
- Have you fully implemented the sliding fee discount program requirements?
- Have your billing and collection policies struck the balance between maximizing reimbursement and maintaining optimum access?
- Is your financial management system sufficient for federal accountability purposes?
- Is your Board of Directors exercising required authorities and meeting its composition requirements, and do you have documentation to verify compliance?
Join FTLF for this hands-on training covering:
- The Chapters of the Compliance Manual, including the elements of each, the documentation required to verify compliance, and areas where health centers retain explicit discretion and flexibility;
- The on-site evaluation tool - the Site Visit Protocol - including assessment methodologies designed for various elements;
- Updates to the OSV and Service Area Competition (SAC) and Look-Alike Renewal Designation (RD) review processes;
- Key hotspots under the new guidance; and
- Compliance tips from our presenters’ years of experience working first-hand with health centers.
- Health Center Executive Staff
- Clinical Leadership
- Quality and Credentialing/Privileging Staff
- Financial Leadership and Staff
- Compliance Officers
- Board members
- Other Staff assisting with HRSA compliance and/or OSV preparation
Given the possible consequences of non-compliance, including 1-year project periods for non-compliance with a single element and potential loss of 330-grant funds, it is critical that every health center be and remain vigilant whether you are expecting an OSV, submitting your SAC / RD application, or looking to bolster current operations as part of ongoing compliance efforts.
After this training, you will be able to:
- Understand the elements of the HRSA programmatic requirements addressed in the Manual and the SVP.
- Identify the specific steps necessary to demonstrate compliance and areas where health centers retain discretion.
- Discuss the newest developments in the OSV and application review processes from an insider’s perspective.
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A partner at the firm, Marcie specializes in health care law, particularly in the areas of federal grants, grant-related requirements and grants management related to the federal health center program. Health centers turn to Marcie as a resource for knowing not only the letter of the law, but also the likely interpretation of requirements by federal policymakers, including the Health Resources and Services Administration (HRSA). [Full Bio]
A partner in the firm’s health law practice group, Molly advises health centers on the management of clinical, employment and workforce-related risks, with a particular focus on professional liability, Federal Tort Claims Act, and HIPAA matters. From her experience as both a private attorney and in-house counsel, Molly knows the importance of managing liability and risk issues in mission-driven organizations. [Full Bio]
Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted is a national authority in the area of federal grants, particularly in the health and community service spheres. He advises clients on all aspects of program requirements, including issues such as cost-based reimbursement, governance and the never-ending list of grant administration matters. Ted’s expertise in financial, cost reporting, reimbursement, and administrative issues is widely recognized and he routinely handles government audits, internal investigations, and litigation. [Full Bio]
Participants can earn up to 15.6 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.
- Prerequisites: None
- Target Audience: Health Center Executive Staff, Clinical Leadership, Quality and Credentialing/Privileging Staff, Financial Leadership and Staff, Compliance Officers, Board members, Other Staff assisting with HRSA compliance and/or OSV preparation
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group-Live
Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).
- 15.60 CPEFTLF is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors.
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