Other – CHC Resource Page

Although the 19 health center key requirements encompass much of health center’s resource needs there are a few topic areas that do not directly fall under one specific key requirement. These topic areas are addressed below.

Risk Management/Compliance

Managing risk and monitoring your CHC’s compliance efforts is essential given the current healthcare environment. Risk management and compliance are not the same things:

  • Risk management is a system of procedures designed to reduce exposure to and possibility of certain types of liability, as well as managing potential and actual risks that occur.
  • Corporate compliance is a risk management component that is an internal process used to detect and resolve fraud, waste, and abuse through self-identification and self-correction. The seven elements of an effective compliance program are (adapted from a resource by the Office of the Inspector General (OIG), Department of Health and Human Services (HHS), 2000):

 

  1. Conduct internal monitoring and auditing
  2. Implement compliance and practice standards
  3. Designate a Compliance Officer or contact
  4. Conduct appropriate training and education
  5. Respond appropriately to detected offenses and develop corrective action
  6. Develop open lines of communication
  7. Enforce disciplinary standards through well-publicized guidelines

 

Tools and Resources

The ECRI Institute, which is free for CHCs to access, has a multitude of resource to assist with risk management. Most of the tools are focused on clinical risk but could be adapted depending on the need.

There are a variety of resources available to assist CHCs in developing, implementing and maintaining a compliance program.

 

General compliance resources that are not specifically targeted to CHCs include the following:

Further resources are posted in the members-only section of CCHN’s website.

Operational Site Visits

The Health Resources and Services Administration’s (HRSA) Bureau of Primary Health Care (BPHC) utilizes Operational Site Visits (OSV or site visit) to verify CHC compliance with the Health Center Program Requirements. Both CHC grantees and Look-Alikes routinely undergo site visits, which are conducted by consultants who assess the CHC’s administrative, financial, clinical and governance practices. The following tools and resources can help CHCs prepare for, survive and thrive from a site visit. Don’t see what you’re looking for? Contact Suzanne Smith.

 

Resources Explaining the OSV Process

 

Resources to Help Prepare for the OSV

 

The following resources are only available to CCHN members. In order to access these resources, CHCs need the member username and password. Please contact Suzanne Smith if you need this information. 

  • Tip sheets for the top six areas with findings in 2016. To access the members only page, click here.
  • CHC staff who participated in recent OSV presented about their experiences to their peers in several meetings over the past two years. Recordings of these presentations and the slides used during the presentations can be found here.
  • Examples of tools that CHCs have utilized to help prepare for an OSV can also be found in the technical assistance section of the members only side of the CCHN website.

340B

Created in 1992, the 340B Drug Pricing Program aims to provide discounts on prescription drugs to select safety net providers, including CHCs and Look-alikes. Resources provided below aim to inform CHCs on the development, certification and management of their 340B program.

 

FTCA

The Federal Tort Claims Act (FTCA) has long been the legal mechanism for compensating those who have suffered personal injury due to the negligent or wrongful action of employees of the U.S. government. Under Section 224 of the Public Health Service Act, employees of eligible health centers may be deemed to be federal employees thereby qualifying for protection under the FTCA.

 

Eligible health centers must submit an original deeming and annual renewal deeming application in order to be covered. The CY2016 requirements for FTCA redeeming/deeming have been released in PAL 2015-03; click here to view. This FTCA Deeming Application Tip Sheet for calendar year 2016 Health Center FTCA Application is a resource that may help with completeting the FTCA application as it walks through each section in detail and includes what each form and attachment should include.

 

While FTCA provides coverage for most of what is needed, there continues to be gaps that CHCs should be prepared for. It is recommended that CHCs acquire gap coverage for scenarios such as: prior acts, moonlighting activities, coverage for part-time contractors, volunteers, Good Samaritan coverage, out of scope activities, residents in training, other care to non-CHC patients, etc.

 

ECRI Institute

Clinical Risk Management and Credentialing Programs

ECRI offers free resources to CHCs, including the Event Reporting Toolkit and Risk Management Plan with step-by-step guides to implement these key programs, Credentialing Toolkits, and sample policies and a tools library with templates and examples.

 

Additional policies can be found here.

HIPAA

The HIPAA Privacy Rule, enacted in 1996, creates a minimum standard for protecting the privacy of individually identifiable health information. This rule focuses specifically on electronic protected health information (ePHI) and provides set administrative, technical, and physical standards to protect ePHI. The following tools and resources can assist CHCs prepare, review and improve their HIPAA related activities.

 

ICD-10

The International Classification of Diseases (ICD) is the standard coding system for epidemiology, health management and clinical purposes. Due to the Protecting Access to Medicare Act of 2014 (PAMA) the date at which ICD-10 will be replacing ICD-9 for medical coding will be implemented in October, 2015. At that time all entities covered by the Health Insurance Portability and Accountability Act (HIPAA), must implement ICD-10. The resources provided below aim to assist CHCs in preparing for ICD-10 implementation.

As part of ICD-10 transition preparation it is recommended that CHCs participate in end-to-end testing. End-to-end is essential to assure compliance and uninterrupted flow of transactions with trading partners and vendors. CMS offers several of resources to learn more about this important process.

Look-Alike Clinics

Community Health Center Look-Alikes (Look-Alike), just like funded Community Health Centers, provide services to low-income, underserved populations and follow the same Health Center Program Requirements. However, Look-Alikes do not receive any funding through section 330 of the Public Health Service (PHS) Act to provide services to uninsured users. More about the Look-Alike model, and how it compares to the section 330 CHC model, can be found here.

 

The majority of resources available on CCHN’s website apply to Look-Alikes. However, there are differences in the application procedure for Look-Alikes as well as minor differences in Uniform Data System (UDS) reporting. These differences include:

 

 

In addition to these resources, BPHC includes further information and technical assistance on Look-Alikes here.

 

Patient Centered Medical Home

For resource pertaining to Patient Centered Medical Home transformation go to CCHN’s Quality Initiatives Division page or click here.