Management and Finance – CHC Resource Page

Health Center Program Requirements 9 through 16 mandate how Community Health Centers (CHC) are managed, exercise oversight and authority, and maintain accounting/internal control systems.

Key Management Staff

According to the HRSA Health Center Program Requirements, Program Requirement 9 states, “Health center maintains a fully staffed health center management team as appropriate for the size and needs of the center. Prior approval by HRSA of a change in the project director/executive director/CEO position is required.” CHCs are required to have appropriately sized executive leadership teams to carry out the mission and vision of that CHC. NACHC in partnership with the Illinois Primary Health Care Association provide a resource that assists in understanding this program requirement; click here to view.

    • Examining Requirement 9: Key Management Staff: The Illinois Primary Health Care Association published this article on HRSA’s Program Requirement 9: Key Management Staff to provide an in-depth look at Program Requirement 9. This article discusses the different aspects of this requirement, and suggests questions to aid in improving CHC performance on this requirement. 

Contractual & Affiliation Agreements

CHCs are expected to maintain appropriate oversight and authority over all affiliations and contracts, such as contracts with other types of health care organizations that assist CHCs in providing services.

 

BPHC provides guidance on this requirement in:

 

The Illinois Primary Health Care Association explored this requirement in-depth in the article Examining Requirement 10: Contractual/Affiliation Agreements which provides a description of the requirement, as well as performance improvement suggestions

 

As well, there are Federal procurement grant regulations that CHC staff should be aware of as it relates to contacts and affiliations. These regulations are detailed in the 45 CFR Part 74.41 to 74.48, which are the Department of Health and Human Services’ uninform administrative requirements for awards and sub-awards to institutions of higher education, hospitals, other nonprofit organizations, and commercial organizations.

 

NACHC has published several resources on the topic of contracts and affiliations:

Collaborative Relationships

CHCs are expected to establish and maintain collaborative relationships with other health care providers within their service area, including other CHCs. Similar to expectations outlined in Health Center Program Requirement 10: Contractual/Affiliation Agreements, the intent is that these collaborative relationships help ensure CHC patients have access to appropriate health care services. These collaborative relationships can be documented through letters of support, memoranda of agreement/understanding, or other types of documentation of a collaborative relationship.

 

BPHC provides guidance on this requirement in PAL 2011-02: Health Center Collaboration. Other resources on this subject include:

  • The Illinois Primary Health Care Association explored this requirement in-depth in the article Examining Requirement 11: Collaborative Relationships. The article provides a description of Requirement 11, and poses questions to ask when considering if you CHC complies with this requirement.
  • CHCs can utilize the tools available in UDS Mapper in order to identify some of the other types of health care providers that operate within their service area. 

Financial Management and Control Policies

NACHC offers a CFO Accounting Policies and Procedures Manual. The manual is organized into eight sections and includes a Policies and Procedures Manual section. Other sections include explanations of the roles, responsibilities and priorities of a CHC CFO, operational issues (A/R, budgeting, revenues expenses, etc.), regulatory requirements of CHCs, managing grants, practice management systems and more.

 

The Health Resource and Services Administration (HRSA), in partnership with the Office of Federal Assistance Management, published the Tip Sheet for HRSA Grantees: A Guide for Developing Effective Financial Management Practices. This one-page guide briefly outlines baseic practices that shoul dbe followed to ensure that no CHC has to return grant funding due to spending it on unallowable costs.

Billing and Collections

There are several resources available through the Colorado Department of Health Care Policy and Finance website. To access these resources follow the links below.

NACHC offers a FQHC Billing Manual for a fee. This manual supports CHCs efforts to increase efficiency, and accuracy in the billing and collections process.

 

As of October 1, 2014, CHCs will transition to a prospective payment system (PPS) in which Medicare payment is made based on preset, fixed amounts. In order to help prepare CHCs for this transition NACHC, in partnership with BKD and FTLF, generated two free webinars covering Medicare basics, the new PPS regulations and what requirements will remain the same post implementation. Although these webinars are free to all interested parties there is some login information required.

Budget
Content coming soon! 
Program Data Reporting Systems

CHCs are required to have systems in place to collect and organize data for program reporting. All CHCs are required to prepare a Uniform Data Systems (UDS) report for every calendar year. These reports provide data on staffing, services, and financing for all BPHC funded programs.

  • 2013 UDS Training Manual :This resource is published by the Bureau of Primary Health Care (BPHC) and provides detailed instructions for UDS reporting for data from Calendar Year 2013. 
  • 2013 UDS Tables: This document compiles all tables that CHCs are required to report on. 

Scope of Project

CHC’s are expected to have a scope of project that encompasses the health care services, administrative and clinical sites, service area, target population, and staff that are supported by Section 330 grant funds or a CHC Look-Alike Designation. Having a defined and accurate scope of project is important because:

 

  1. Section 330 grant funds can only be used to support “in scope” work, i.e. work that is defined by and in support of the CHC’s scope of project.
  2. Malpractice coverage through the Federal Tort Claims Act (FTCA) only covers the CHC’s scope of project.
  3. A CHC participating in the 340B Drug Pricing Program need to ensure any listed service sites are within the approved scope of project.
  4. HRSA’s position is that CHCs can only seek Medicaid and Medicare reimbursement under the enhanced rates for services provided to eligible Medicaid and Medicare patients at the sites listed in a CHC’s scope of project.

 

Each CHC must define their scope of project in applications to HRSA through Form 5: Required and Additional Services, Form 5B: Service Sites, and Form 5C: Other Activities/Locations. It is highly recommended that CHCs regularly review these documents to ensure they are up to date and accurate, including that the documents reflect any changes a CHC institutes due to new grant awards or changes in the types of services needed by the CHC patients. If necessary, a CHC must submit a Change in Scope request in order to update the scope of project to reflect any changes that are documented on Forms 5A, 5B and 5C.

 

HRSA has posted a variety of resources to provide guidance around the scope of project requirements, all of which can be found through the main Scope of Project webpage.

 

In particular, the following documents should be reviewed in detail to ensure understanding of what the scope of project entails:

 

 

Any changes in a CHC’s scope of project must be made at least 60 days before the intended date of implementation through a Change in Scope (CIS) request and are required for:

  • Adding a new service or service delivery site
  • Terminating an existing service or service delivery site
  • Adding a new target population

 

In order to submit a CIS request, the CHC must document that there is or will be adequate revenue to cover all costs associated with making a change to a CHC’s scope of project. This is because any changes to a CHC’s scope of project must be completed and sustained without additional Section 330 grant funds. As well, there must be record in the board minutes that the CHC’s governing board has reviewed and approved what the proposed change in scope entails, including reviewing any financial analysis done for the CIS request. HRSA has created to resources to assist with financial analysis performed for a CIS request:

 

 

A CIS request is submitted via the Electronic Handbook (EHB) and details about the submission process can be found in the CIS EHB User Guide and under the categories of Service Changes, Site Changes, Target Population Changes, Other Activities Change Form on the Scope of Project webpage.

 

It is possible to submit a CIS request to add a temporary location in response to emergency events. The circumstances when this type of request can be submitted, as well as timeline and submission requirements for the temporary change in scope are outlined in PAL 2014-05: Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events.