De-Mystifying the New Compliance Manual & Its Impact on the Program Requirements
In August 2017, HRSA issued the Health Center Program Compliance Manual, providing a streamlined and consolidated resource to assist Federally Qualified Health Centers (FQHCs) in understanding and demonstrating compliance with their programmatic requirements. The Manual replaces several Policy Information Notices (PINs) and Program Assistance Letters (PALs), merging prior guidance into one document that explains the statutory and regulatory mandates of each requirement, which collectively form the framework of every health center’s specific program. The Manual also incorporates a new approach to “everyday compliance,” addressing the elements and documentation necessary to verify compliance with each requirement as well as explicit areas of health center discretion and flexibility.
Recently, HRSA issued a new Site Visit Protocol aligned with the Manual and reflecting a more objective assessment tool for use during both Operational Site Visits (OSVs) and on-site reviews for initial FQHC Look-Alike Designations. Of importance, the Manual has been effective since publication in August 2017 AND HRSA has announced its intention to start using the new Protocol for all on-site assessments taking place after January 22, 2018. Is your health center prepared for the changes to HRSA programmatic compliance and the on-site assessment process based on these new guidance documents? Have you implemented all of the elements addressed in the Manual and established your HRSA compliance work-plan consistent with the Protocol? Specifically,
- Do you have written agreements in place for services provided via contract and/or formal referral and do your agreements include all required provisions?
- Are your providers appropriately credentialed and privileged and do your quality improvement systems 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 accountability purposes?
- Is your Board of Directors exercising all of its authorities and meeting other governance requirements?
Given the potential consequences of non-compliance (including draw-down restrictions and re-competition of your grant), it is crucial that every health center prepare itself by reviewing its knowledge and implementation of all core requirements as described in the Compliance Manual and the Site Visit Protocol.
Join FTLF Partners Marcie Zakheim and Molly Evans and Managing Partner Ted Waters for this hands-on training as they walk health centers through the key differences between the prior guidance and the Compliance Manual, focusing on the elements of the requirements, the necessary documentation to verify compliance, and the areas of health center flexibility and discretion that may impact operations. Participants will discuss updates to the on-site assessment process, and explore key hotspots (both old and new) that have emerged from the field regarding governance, administration and finance, as well as “tricks of the trade” from our presenters’ years of experience working with health centers. Whether or not you have an OSV on the horizon, this is a must-attend workshop for establishing an environment and culture of ongoing compliance.
- Health Center Executive Staff
- Clinical Leadership
- Human Resources Staff
- Financial Leadership
But all are welcome!
At this training participants will:
- Understand the key differences between the prior guidance and the new manual and its impact on OSVs.
- Understand the specific steps necessary to demonstrate compliance and areas where health centers retain discretion.
- Learn which PINs and PALs have been replaced by the new manual and which current guidance is still effective.
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]
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]
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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Available payment methods include purchase order, check, and credit card. Payment for this live training is due 2 weeks before the start of the event. If payment is not received in full 2 weeks prior to the start of the event, your order will be cancelled and you will be denied entrance to the training.
Cost for this 2 Day Training:
Early bird rate (until March 24): $795 per person
Regular registration (after March 24): $845 per person
Cancellation Policy for this Event:
All cancellation requests must be received in writing.
All cancellations prior to March 23, 2018, will receive a full refund.
All cancellation requests received between March 24, 2018 and April 10, 2018 will receive a 50% refund.
All cancellation requests received after April 10, 2018 will not be eligible for a refund.
To cancel your reservation, please send a request in writing to Learning@FTLF.com.