(Recorded Webinar) Document Deep Dive - Purchase of Services Agreement: Checklist and Referral Agreement: Checklist
The Health Center Program mandates that in-scope services, as listed in a health center’s Form 5A, are provided directly by the health center, by contract, and/or by referral. If a health center achieves such access via contract and/or referral, then the health center must maintain a written agreement with the other provider (i.e., a Purchase of Services Agreement and/or a Referral Agreement). There are a myriad of provisions that must be addressed in such written agreements in order to achieve HRSA compliance. For example, Purchase of Services Agreements must address record retention and programmatic reporting obligations, and Referral Agreements must describe how referrals will be made and managed. In addition, both Referral Agreements and Purchase of Services Agreements must include certain representations regarding fee discounts and provider credentialing/privileging.
In practice, inadequate Purchase of Services Agreements and Referral Agreements is one of the most common reasons for non-compliance findings stemming from Operational Site Visits. Drafting Purchase of Services Agreements and Referral Agreements that include the necessary provisions can be challenging, in part because the applicable requirements are described in multiple Chapters within the HRSA Health Center Program Compliance Manual.
Health centers are accordingly encouraged to become familiar with the applicable requirements and confirm that their respective Referral Agreements and Purchase of Services Agreements include the necessary provisions.
Join Marcie Zakheim and Carrie Riley for a deep dive into FTLF’s Purchase of Services Agreement: Checklist and Referral Agreement: Checklist.
This session will walk through these checklists to:
- Explain the three service delivery methods within the Form 5A;
- Explain the required provisions and highlight the applicable element from the HRSA Health Center Program Compliance Manual;
- Discuss drafting alternatives that satisfy the underlying HRSA requirement;
- Review optional yet recommended provisions; and
- Discuss common pitfalls and strategies to overcome them.
Whether you have been using FTLF’s checklists for years, are a Section 330 Health Center Program Toolkit subscriber, or are looking for support to strengthen your agreements and comply with requirements, this Document Deep Dive will provide valuable information and insight for your health center.
Always complimentary for Premium Plan subscribers, each Document Deep Dive (including the recording and the sample document) is also available for purchase by health centers, behavioral health organizations and other direct care organizations.
Please note: this Document Deep Dive has been developed specifically for health centers, health center look-alikes, behavioral health organizations and other direct care organizations. If you do not fall into one of these categories and would like to register for this training, please contact the FTLF Training Team.
Carrie Riley is a Partner in the health law, non-profit and corporate law, and federal grants law practice groups. She counsels a wide variety of health care clients, including Title X grantees and subrecipeints, and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. Prior to going to law school, Carrie worked at a Title X regional training center for several years. [Full Bio]
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]
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