While the two documents are not harmonized, we recommend the more conservative approach of having both a guideline for following recommendations and referring to the process in the written recommendation agreement. Stay tuned for more common compliance pitfalls! Note: The same sample of referral agreements will be used to review required and additional health services, clinical staff and the rolling expense reimbursement program. Fellows must ensure that all agreements/contracts/arrangements with other suppliers and organizations comply with the requirements of section 330 and the By-law of the Department of Health and Social Services.11 Grant recipients must also ensure that providers are duly qualified and authorized for formal agreements/arrangements in order to carry out the activities and procedures expected by the recipient. be carried out. The required primary health services must be provided directly by the beneficiary or by a specified agreement10, e.B. by a formal agreement or by a reference formal agreement. In addition, the necessary services, provided directly by the beneficiary or through formal agreements or formal reference agreements, must be offered on a sliding scale of fees and be equally available to all patients, regardless of their creditworthiness. Therefore, informal referral agreements for the provision of a required service are unacceptable. The HRSA Compliance Manual states that how recommendations are made and managed should be addressed in formal reference agreements, but the site visit protocol simply asks whether the health centre has a process for creating, managing, and tracking recommendations.
Health centers almost always have reference processes (which meet the SVP standard), but rarely the process of following up on recommendations in contracts (to meet the compliance manual standard). Note: The same sample of contracts or agreements will be used for the review of required and additional health services, clinical staff and the rolling expense reimbursement program. Sampling methods for required and additional health services are different from contracts and sub-awards and conflicts of interest, although they can lead to overlaps in contracts/agreements. If these provisions are not included in the referral agreements, provide additional documentation (e.g.B. Standard Operating Procedures for Health Centres) containing these provisions. How recommendations are formulated and managed; and under such formal reference agreements, if the actual service is provided and paid/billed by another entity, the SERVICE is NOT included in the recipient`s project scope. However, the definition of the referral agreement and the follow-up provided by the beneficiary after the transfer shall be considered to be part of the scope of the beneficiary`s project. For example, a fellow may have a reference agreement for diagnostic X-rays with a hospital. As part of the referral agreement, the hospital performs the diagnostic X-ray, bills the patient for the services, and provides feedback and/or results to the recipient for appropriate follow-up. The diagnostic X-ray service would NOT be part of the recipient`s project scope, but the implementation of referral and follow-up by the recipient would be within the scope of the recipient`s project. Note: The tax expert also reviews contracts/agreements and agreements to assist the clinical expert in assessing the scope of project accuracy for element “a”. Note: FtCA and 340B coverage on drug prices does not extend to all types of contracts and reference agreements.
Healthcare centers should refer to the FTCA guidelines listed on page 26 of this PIN and the Federal Register, Volume 61, No. 207, page 55156-8, “Patient and Entity Eligibility,” to clarify the price advantage of 340B drugs for referrals. Keep in mind that the FTCA and 340(B) each have their own independent requirements that must be met to participate. While the development of HRSA`s new compliance manual and on-site visit protocol has removed much of the subjectivity of the operational site visit process, there are still some areas that are confusing for health centers. In future blog posts, our team will highlight some of these areas and give our opinion on how best to deal with these common issues. This week, we`re going to highlight a common issue regarding reference tracking policies and benchmark agreements. When reviewing the various health center compliance documents, the astute observer will find that there is a slight difference between the site visit protocol and the HRSA compliance manual in terms of reference tracking policy requirements. The HRSA Compliance Manual states: “Formal Written Reference Agreement: If access to a required or additional service is provided and billed by a third party with whom the Health Centre has a formal Referral Agreement, that service will be accurately recorded in Column III of Form 5A: Services Provided, indicating that the Health Centre is responsible for referring patients from the Health Centre and any care of follow-up for these patients who are served by the health center after referral.
In addition, the health centre ensures that these formal referral agreements for services are addressed at least to the address: The on-site visit protocol requires: “Does the health centre have a process for creating, monitoring and managing referrals for these services with the referral provider(s.B. Procedures for following up if the patient has been presented to the reference provider or the results of the reference visit?? (Chapter 4: Required and Additional Services, Element A., Question 3) f. Immigration voucher screening sites Immigration voucher systems are established when there is not enough sustainable demand for health services from migrant and seasonal agricultural workers in an area to justify the establishment of a permanent or seasonal place of service. Migrant voucher recipients often do not provide direct health services; Instead, the recipient may set up one or more screening sites where a patient`s clinical needs are assessed, and then a referral for care to a local provider is made under a specified contractual agreement. The local provider provides primary care services to those recommended by the voucher program. Under these agreements, services are provided on behalf of the health centre through a contractual agreement. However, services under contracts are generally not provided on a regular basis, but as required. Health centres may also provide “additional health services”, which are defined in section 330 of the Act as “services that are not included as required primary health services and that are appropriate to meet the needs of the population served by the health centre.” 8 Fellows are reminded that once a service has been included in the scope of the approved project, it must be provided to all patients. are also available regardless of creditworthiness and are available through a sliding scale of fees.9 Fellows should therefore carefully assess the costs, benefits and risks to the beneficiary before providing these services. In general, a recipient must demonstrate that all required primary health services are available to all patients before proposing to add additional health services. Information on the recipient`s target population must be included on Form 4: Community and Target Population Characteristics.
Demographic, income, insurance status and other information on the coverage area and target population should be recorded on this form in aggregate form for the entire beneficiary and not on a location-by-site basis and updated at least once a year in the recipient`s federal funding application. Patients in health centres with limited English language proficiency (LEP) receive interpretation and translation services (para. B through bilingual providers, on-site interpreters, high-quality video or telephone remote interpretation services) that provide them with adequate access to health centres. Fellows must list intermittent locations as a category on Form 5 – Part B: Service Locations. Specific locations where the Fellow establishes an intermittent location for the provision of services do not need to be listed. However, the number of these locations should be listed on Form 5 – Part B: Service Locations and be updated at least once a year in the recipient`s federal funding application. The type and number of clinical providers, including volunteers and other staff, must be listed on Form 2: Staff Profile. Suppliers and other employees are reported in total for the beneficiary, not on a site-by-site basis. Providers should be updated at least once a year in the recipient`s application for federal support. The concept of service or “catchment area” has been part of the health centre`s program since the very beginning. Although the service area is usually the area where the majority of patients in the health centre live, health centres may use other geographical or demographic characteristics to describe their coverage area. The Health Center Program Authorization Act requires each fellow to regularly review their catchment area: for each service provided under Column III (whether or not the service is also provided through Column I and/or Column II): c.
Seasonal Service Sites Due to the seasonality of employment, accommodation or mobility of the patients being cared for, Fellows may plan certain service sites seasonally or for a single part of the year. Seasonal locations meet the above definition of a service location, but work at a fixed location for less than 12 months per year. .