De-Mystifying the Compliance Manual & Its Impact on the Program Requirements
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In August 2017, HRSA issued the Health Center Program Compliance Manual (the Manual), replacing most prior guidance with a consolidated resource to assist Federally Qualified Health Centers (FQHCS) in understanding and demonstrating compliance with their programmatic requirements. The Manual incorporates a new approach to “everyday compliance” by addressing each requirement’s statutory and regulatory basis, the key elements of compliance that collectively form the framework of every health center’s project, the documentation necessary for verification and areas for which health centers maintain discretion.
In late December 2017, HRSA issued a new Site Visit Protocol (the SVP), which aligns with the Manual and reflects a more objective compliance assessment tool. Both the Manual and the Protocol are currently in effect, being used by HRSA for on-site reviews of grantees and FQHC look-alike entities (Operational Site Visits - OSVs) and 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;
- Key differences between prior guidance and the Compliance Manual;
- The new on-site evaluation tool - the Site Visit Protocol - including assessment methodologies designed for various elements;
- Updates to the Operational Site Visit (OSV) review process;
- 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 or submitting your Service Area Competition / Look-Alike Designation Renewal application in the near future, or you are looking to bolster your current operations as part of an ongoing HRSA compliance effort, this training is for you!
At this training participants will:
- Understand the elements of the HRSA programmatic requirements addressed in the Manual and the SVP and their impact on OSVs and application reviews.
- Understand the specific steps necessary to demonstrate compliance and areas where health centers retain discretion.
- Learn the key differences between prior guidance and the Manual/SVP, including which PINs and PALs have been replaced and which are still effective.
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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 focuses his practice on helping organizations to solve problems, often in crisis situations. 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 illustrated by his selection as a 2014, 2015, and 2018 Washington, D.C. Super Lawyer in health care. Ted routinely handles challenging issues for clients such as government audits, internal investigations, and litigation, deftly guiding them to a resolution. His priority is to help each organization carry out its mission and ensure that legal challenges do not distract from that focus. From his more than a decade of experience running the firm, Ted understands acutely the challenges of keeping an organization running, and offers practical, down-to-earth counsel to support organizational leaders in doing just that. [Full Bio]
Conference participants can earn up to 14 CPE credits in Specialized Knowledge and Applications.
- Prerequisites: None
- Target Audience: Health Center Executive Staff, Clinical Leadership and Human Resources Staff, but all are welcome.
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group-Live
Feldesman Tucker Leifer Fidell 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.learningmarket.org.
- 14.00 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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Cost for this 2 Day Training:
Early bird registration (until June 25): $875 per person
Regular registration (June 26 - August 19): $950 per person
Late registration (August 20 - September 4): $1000 per person
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