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FQHC Series: Documenting Services Provided

FQHC Series: Documenting Services Provided

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Federally Qualified Health Centers (“FQHC”) and Community Health Centers (“CHC”) (hereafter collectively referred to as “the Centers”) are safety net providers that serve the most vulnerable consumers of healthcare in America by providing necessary services without consideration of their ability to pay.

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

The first part of this series discussed documentation to be maintained by FQHCs and CHCs to comply with the first requirement, “Have a written Needs Assessment”.  We will now look at the requirements for and best practices to comply with the second compliance requirement “Service”.

Services comprise one of five elements that define the project scope of FQHCs and CHCs. While services may differ from one health center site to another, all clients must have access to included services, irrespective of ability to pay. Section 330(a) and (h)(2) of the PHS Act states that the health center must provide all required primary, preventive, enabling health services  and additional services as appropriate and necessary, either directly or through established written arrangements and referrals.

If the health center receives section 330(h) funding/designation to serve homeless individuals and their families, substance abuse services must be provided either directly and/or through formal written agreements or formal written referral arrangements.

The following documents are required to demonstrate compliance

  1. Form 5A: This is the health center’s official scope of project for services. If there is a change in scope during the year, the updated form 5A, including scope adjustment questions and change in scope assurance should be retained
  2. Written agreements relating to arrangements or referrals for services that are provided through other service providers.
  3. Clinical practice protocols and/or other policies and procedures that support the delivery of health center services which includes how patients will be billed; and how the Center’s policies and/or procedures will apply as appropriate
  4. A referral tracking policy/procedure must be in place that indicates how patients are referred for services outside of the center and the process for returning the patient with a report of those services to the Center for follow up care.
  5. Tracking policy/procedure for laboratory and radiology services. Contracts must be in place to assure access to patients for these services and a process should be in place to submit reports of service to the center to inform follow-up care.
  6. Contracts with pharmacy
  7. If the target population is culturally and linguistically diverse, interpretation/translation services should be provided. The same applies to clients with disabilities. Documents or messages vital to a patient’s ability to access health center services (e.g., registration forms, Sliding Fee Discount Schedule, after-hours coverage instructions, signage, etc.) are provided to patients in the appropriate languages, literacy levels, and/or alternative formats (for patients with disabilities) and in a timely manner.

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. For example, if your health center changed its scope of services, has your Form 5A been updated? Are the services you are currently providing consistent with that listed in your Form 5A?  Have your health center referral arrangements been documented with a memorandum of understanding (“MOU”) or Agreement (“MOA”)? Are your center’s MOUs and MOAs up to date reflecting all relevant changes?

This is an area where a site visit contractor will perform review of your center’s documentation in advance of the site visit.  Additionally, since many health centers provide services to patients where English is a second language, it is important to ensure that your center provides multi-lingual communication of items critical of the patients’ access to healthcare in a timely manner. Some good examples of a FQHC or CHCs compliance here are multi-lingual notices throughout the center, registration documents in multiple languages and having sign language services available for those with hearing disabilities.

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 third compliance requirement “Staffing”.

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