(Recorded Webinar) Part VI: Providing Quality Care Through an Appropriate Clinical Staffing Model
PART VI: Credentialing & Privileging and Quality Improvement / Assurance
The final part (Part VI) of the De-Mystifying the Compliance Manual webinar series will address the health center program requirements related to the processes that ensure quality of care and appropriate verification of the professional qualifications of your clinical staff. On this webinar, we will explore credentialing and privileging for all members of the clinical staff, including the required assurances necessary to verify the credentials and privileges of contractors. In addition, we will also discuss health center requirements for continuous, ongoing quality of care programs and plans.
This final webinar will focus on topics from the following chapters of the Compliance Manual:
- Chapter 5: Clinical Staffing
- Chapter 10: Quality Improvement/ Assurance
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 (issues 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.
- Health Center Executive Staff
- Clinical Leadership
- Quality and Credentialing/Privileging Staff
- Administrative / operations leadership and staff
- Compliance Officers
- Board members
- Other Staff assisting with HRSA compliance and/or OSV preparation
After this webinar series, you will be able to:
- Understand the credentialing and privileging requirements, specifically how they apply to Licensed Independent Practitioners (LIPs), Other Licensed or Certified Practitioners (OLCPs) and other clinical staff members.
- Discuss the requirements for quality improvement/assurance (QI/A) programs and identify such program’s relationship to overall compliance.
- Assess whether your policies and procedures related to both credentialing & privileging and QI/A meet current HRSA requirements.
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]
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