FQHC Series: Accessible Hours of Operations / Locations
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 18 HRSA program requirements. All 18 of the requirements can be found on HRSA’s website listed here. (Note : In the August 28, 2017, Health Center Program Compliance Manual released by HRSA, the 19 program requirements were replaced with 18 requirements spread across 21 chapters of the Compliance Manual).
The earlier parts in this series discussed how FQHCs and CHCs comply with HRSA’s requirements related to Needs Assessment, Services and Staffing. We will now look at the requirements for and best practices to comply with the next compliance requirement “Accessible Hours of Operations / Locations”.
Based on the scope of services, and sites where these services are provided, as documented on Form 5B, the health center must provide services at times and locations that assure accessibility and meet the need of the population to be served. (Section 330(k)(3)(A) of the PHS Act).
The health center would demonstrate compliance with these requirements by ensuring that
- The times that services are provided at sites are reasonably appropriate to ensure access to the population to be served.
- The locations (as documented on Form 5B) at which services are provided are accessible to the population to be served.
All health centers that receive targeted funding /designation to serve designated medically underserved populations/areas or special medically underserved populations comprised of migrant and seasonal farmworkers, homeless or residents of public housing must make the services available in areas immediately accessible to the targeted public housing communities. Health Centers have discretion in determining which methods to use for obtaining patient input on the accessibility of its service sites and hours of operations (for example, annual survey, focus groups, input patient Board members).
Your focus on compliance should be to prepare for a site visit. The best way to prepare for a compliance review is to ask yourself the questions contained in the health center site visit guide.
- Accessible Service Sites
Does the health center take the following factors, including those specific to special population(s) (if applicable), into consideration in determining where to locate its sites (for example, the health center has considered the ways patients access health center sites; distance and time taken for patients to travel to or between service sites in order to access the health center’s full range of in-scope services).
- Accessible Hours of Operation
Has the health center taken patient needs into consideration in setting the hours of operation of its sites (e.g., The health center’s total number and scheduled hours of operation across its service sites are responsive to patient needs by facilitating the ability to schedule appointments and access the health center’s full range of services within the HRSA-approved scope of project. A health center service site might offer extended evening hours 3 days a week based on input or feedback from patients who cannot miss work for appointments during normal business hours, input may also be obtained from an annual survey or input from patient Board Members).
- Accurate Documentation of Sites within Scope of Project
Was the health center able to attest that its Form 5B is an accurate reflection of all active sites in scope (e.g., The health center accurately records the sites in its HRSA-approved scope of project on its Form 5B: Service Sites in the HRSA’s Electronic Handbooks (EHB). To ensure accurate recording of scope of project on form 5B, the following field must be completed: site name, physical site address, site phone number, web URL, site type, location type, site setting, date site was added to scope, site operational date, FQHC site Medicare billing number status, FQHC site Medicare billing number, FQHC Site national provider identification (NPI) number, total hours of operation (per week), months of operation, service area zip codes, number of contract service delivery locations (required for migrant voucher screening site type), number of intermittent sites (required for intermittent site type, site operated by, subrecipient or contractor information. Instructions for completing, and explanation of whether and how each field may be updated can be found on the form 5B descriptions and instructions.
These visits are designed to perform a full organizational assessment in all operational areas (fiscal, clinical, administration/ governance). Every health center will have an operational assessment at least once per project period (read every 3 years). Operational assessments are usually 3 days on site and your HRSA Project Officer/Branch Chief may or may not attend. For additional information on these requirements, please review Health Center program Statute Section 330 of the Public Health Service Act (42 U.S.C § 254b); program Regulations (42CFR Part 51c and 42CFR Parts 56.201-56.604 for Community and Migrant Health Centers); Grant Regulations (45 CFR Part 74).
With the right amount of planning and attention to detail, you can put your FQHC or CHC in a good position to comply with this critical HRSA requirement.
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 compliance requirement “After Hours Coverage.”
For more information, fill out the form below and a member of our Healthcare Services team will respond.
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Josue Philistin, CPA, Manager (732) 743 4551 [email protected] |
