FQHC’s: Do I Need A Needs Assessment?
Health centers are defined in the Public Health Services Act (“PHSA”) as “entities that serve a population that is medically underserved, or a special medically underserved population comprised of migratory and seasonal agricultural workers, the homeless, and residents of public housing.”
These health centers enjoy many benefits, including Health Services Resources Administration (“HRSA”) grant money to fund operations, medical malpractice coverage through the Federal Tort Claims Act, enhanced Medicare and Medicaid reimbursement and others. To maintain these benefits, they are also required to operate their centers in accordance with 19 HRSA program requirements. All 19 of the requirements can be found on HRSA’s website listed here:
https://www.bphc.hrsa.gov/programrequirements/summary.html
As a part to this series we will look at each of these requirements to provide some insight on what a site visit team will be looking for, and what you can do to prepare so that your FQHC or CHC is adopting and following best practices and complying with HRSAs requirements. In this part, we will be looking at the first requirement, “Having a Written Needs Assessment.”
Section 330(k)(2) and section 330(k)(3)(J) of the PHS Act govern this needs assessment and the Centers must demonstrate and document the needs of their target population including updating their service area, when appropriate. A site visit contractor’s task will be to document the answers to questions like: “does the center have a written needs assessment? is service area defined? Is the area consistent with that reported in the Universal Data System (“UDS”)?” They will then typically request certain information in advance of the visit to evaluate compliance in this area. A good starting point for the contractor, if this is not your first site visit or first two years of operations, is the needs assessment documentation from the prior visit. Be mindful that a compliant plan will include the following documentation
- Definition of the proposed service area (catchment area)
- Population composition, including;
- Socio-demographics
- Break-down by Federal Poverty Levels
- Percent of population at or below 200% of poverty
- Percent of uninsured population
- Description of current service providers within the area
- Primary care, sorted by Family Practice, Pediatrics, OB/GYN
- Dental
- Mental Health
- Population to Primary Care Physician FTE ratio
- Proximity to providers who accept Medicaid and/or uninsured patients
- Health indicators
A good needs assessment that meets the HRSA criteria will include reference to a variety of activities as well. For example, Centers conducting outreach activities, community forums, focus groups with homeless persons, and research should include these activities in their needs assessment. An important consideration in presenting this information is that it be consistent with patient origin data in the UDS.
As noted above and in every program site visit report, the data must be consistent. The site visit contractor has various tools to determine consistency and must report on it. If the data isn’t consistent, reconsider the documentation you are maintaining and submitting.
The PHSA has specific requirements that the Centers ensure that the size of the catchment area is sufficient to be accessible to the residents and to the extent practical, conform to the boundaries of political subdivisions, school districts and social service programs. A key consideration is the frequency in which the Centers update their catchment areas. You can understand the complexity of compliance with this requirement as factors both within and outside of the Centers’ control can have an impact. Provider service changes and community demographics are some examples of internal and external factors that may impact the catchment area. Centers can comply with this requirement simply by adopting a policy to review its applicability on a routine basis. As a best practice, annually is a good time frame to revisit the catchment area.
Lastly, it is a good idea for the management team and the board of directors to be prepped on what the site visit contractor is going to be looking for. Any site visit will bring interviews of key personnel and stakeholders. A typical visit, depending on the number of sites and complexity of the Centers, could result in interviews with anywhere from 8 to 25 individuals associated with the organization. Personnel like the Chief Executive Officer, Chief Financial Officer and Chief Medical Officer are common interview candidates. Additionally, human resource personnel, front desk clerks, Information Technology specialists, outreach employees, board members and others could also be part of the process. It is important that everyone involved understands their role, the mission of the Centers so that the interviews yield results that demonstrate that the management team, employees and board members understand the target population and their healthcare needs.
Managing the first compliance requirement of a needs assessment can have its challenges, but with a little planning and diligence it can be one that the site visit reports: “Compliance Status: Met”
Follow our FQHC and CHC Withum Weekly Pulse as we continue our series HRSA compliance requirements. Coming soon will be a discussion of the best practices related to the second compliance requirement “Service.”
Ask Our Experts
To ensure compliance with U.S. Treasury rules, unless expressly stated otherwise, any U.S. tax advice contained in this communication is not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
