(Recorded Webinar) Part II: Establishing the Service Delivery Model and Continuity of Care
On Part II of the De-Mystifying the Compliance Manual webinar series, we will focus on the health center program requirements related to establishing and maintaining a responsive and compliant service delivery model that is available and accessible to all patients, including:
- Conducting the needs assessment;
- Establishing a linguistically and culturally appropriate scope of services as well delivery approaches that promote access for all;
- Ensuring ”real” access to care by establishing hours and locations that minimize barriers and are responsive to patient needs;
- Establishing continuity of care mechanisms, such as after-hours coverage and hospitalizations; and
- Working within the community to supplement the center’s scope of services through collaboration and coordination.
This webinar will focus on topics from the following chapters of the Compliance Manual:
- Chapter 3: Needs Assessment
- Chapter 4: Required and Additional Health Services
- Chapter 6: Accessible Locations and Hours of Operation
- Chapter 7: Coverage for Emergencies During and After Hours
- Chapter 8: Continuity of Care and Hospital Admitting
- Chapter 14: Collaborative Relationships
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.
To assist in conducting a “hands-on” compliance evaluation, HRSA issued a Site Visit Protocol (the SVP), which aligns with the Manual and reflects a more objective assessment tool than prior review guides. The current SVP (issued in April 2019), includes additional clarification on documentation requirements and assessment methodologies.
Together, the Manual and the SVP are the main tools used by HRSA for both on-site reviews of grantees and FQHC look-alike entities (Operational Site Visits - OSVs) and “desk audits” of project and designation renewal applications, 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 to verify compliance (both on paper and in practice)
- Areas where health centers maintain discretion
There is an expectation of 100% ongoing compliance with the Health Center Program Requirements. Is your health center prepared to meet this challenge? 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 a grant or look-alike designation application, or looking to bolster current operations and establish your HRSA compliance workplan as part of ongoing compliance efforts.
The On-Demand version of this webinar will be available for purchase after the conclusion of the live webinar.
- Health center executive staff
- Clinical leadership and staff
- Financial leadership and staff
- Administrative / operations leadership and staff
- Compliance officers
- Board members
After this webinar series, you will be able to:
- Describe the elements for the various requirements that together comprise the service delivery model.
- Identify the distinctions between required and additional services, and the different service delivery models.
- Assess whether your Form 5A is accurate and whether your current Form 5A-related contracts and MOUs are compliant with the HRSA requirements related to the provision of services (Chapter 4 only).
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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