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Health Center Program Resources Update

Saturday, February 15, 2014   (0 Comments)
Posted by: Joy Ingram
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by Krista Chuscavage, Member Services Coordinator

In January, I attended NACHC’s New Access Point training in Seattle for Region IX & X newly funded health centers.  Not only did I learn a great amount about the benefits and requirements of being funded by the Health Center Program, I also had the opportunity to hear our newly funded health centers express their top concerns going forward as first-time grantees.  Many of these issues are relevant, and no doubt have always been, for even the most established health centers.  Some of the topics identified have been recently addressed by the Bureau of Primary Health Care (BPHC) or have been noted as current priorities.

These resources could not have come at a more pertinent time for all the new health centers.
On the February 4th all programs quarterly webcast, BPHC announced that 2014 will see funding opportunities for roughly $300 million for expanded services and/or New Access Points.  This is in addition to the $150 million already awarded to 236 New Access Points in November 2013. 

Governance Requirements

New health center grantees specified governance requirements as a top concern.  As you will see on our Resouces page, BPHC has released its FINAL Policy Information Notice (PIN) 2014-1 Health Center Program Governance.  This PIN clarified some long-standing concerns regarding health center governance in regards to board composition, bylaws requirements, the role of the Executive Committee, board requirements for public centers under co-applicant arrangements, and waiver of governance requirements requests.  Some of the questions answered in the PIN were these:

  • What is a health center patient?

Health center patient board members must be current registered patients of the health center and must have accessed the health center in the past 24 months to receive at least one or more in-scope service(s) that generated the visit.  A visit is defined as a documented, face-to-face contact between a patient and a provider who exercises independent professional judgment in the provision of services to the patient.

  • What is needed in terms of non-patient board members?

The non-patient board members must be representatives of the community currently served.  A board must be comprised of members with a broad range of skills, expertise, and perspectives.  No more than one half (50%) of the non-patient board members may derive more than 10% of their annual income from the healthcare industry.

  • What is required for special population patient representation?

Health centers that receive funding/designation under multiple section 330 subparts must have patient representation on the board from the populations targeted and served by the health center.  At a minimum, there must be at least one board member representing each of the special populations for which the health center receives funding.

  • What is an advocate of a special population?

Inclusion of advocates who have personally experienced being members of, represent, have expertise in, or work closely with the special population, however, would meet the requirement for multi-funded/designated health centers to have representation of all the populations for which the health center receives funding/designation. These advocates would not be included in calculating whether the governing board met the patient-majority requirement unless they were also health center patients. Additionally, while advocates may represent special populations on the board as outlined above, health centers should continue efforts to recruit patient board members from the targeted special population.

  • How does the PIN address waivers for governance requirements?

This PIN eliminates waiver requests for any governance requirement other than for the fifty-one percent patient majority governance requirement for eligible health centers.   In the past HRSA has allowed health centers to request waivers of the requirement for monthly board meetings. HRSA will no longer allow waivers for the monthly board meeting requirement, given the improved uses of telecommunications and other information technology to overcome previous geographic barriers to monthly meetings.  Existing waivers of statutory or regulatory health center governance requirements beyond the 51 percent patient majority governance requirement, including those granted under the authority of section 330(e)(1)(B), expire consistent with the effective date of the PIN.

Operation Site Visits

Another major concern the newly funded health centers identified was Operational Site Visits (OSVs).  On the Feb 4th BPHC all-programs webcast, BPHC noted they are planning close to 500 site visits in 2014 compared to the near 400 site visits completed in 2013. 

BPHC has released The Health Center Program Site Visit GuideThe guide is the standardized review instrument used to conduct Operational Site Visits. It includes review questions used by the team conducting the site visit to assess compliance with each program requirement, as well as to review progress on clinical and financial performance and capital grants (if applicable), and, when possible, to identify any best practices established by the health center. Health centers also may use this guide to assess compliance with program requirements and to identify clinical and financial performance improvement areas.

Updates to the OSV guide process include:

  • Questions for assessing and documenting compliance have been clarified and streamlined for all program requirements. In addition, questions for the governance requirements have been updated to align with the 2014 Health Center Program Governance Policy Information Notice.
  • Performance improvement questions have been removed from all program requirement sections. Consultants will focus on performance improvement in the areas of clinical and financial performance.
  • Documents which consultants are expected to review onsite or in advance have been separated from general HRSA resources, such as Policy Information Notices and Program Assistance Letters (PINs and PALs), which are provided as background for each program requirement.
  • The review of clinical and financial performance is now a separate section of the Site Visit Guide.
  • Instructions and questions for assessing and documenting progress and performance on the clinical and financial measures have been clarified and streamlined.
  • A new section and guidance has been added regarding documenting Innovative/Best Practices to align with the standardized site visit report format for Operational Site Visits.
  • Appendix B: Optional Program Requirement/Performance Improvement Summary Grid and Appendix C: Health Center Performance Measures have been removed from the Site Visit Guide

BPHC may have a technical assistance call for the OSV Guide in the future.  Watch the BPHC website for the announcement.

Additional guidance coming soon

Watch for an announcement on the following:

  • FINAL PIN on Sliding Fee Discount Program (Spring 2014)
  • FINAL PIN on Revised Total Budgets from BPHC 
  • BPHC will be releasing a Program Requirements Manual to better clarify what health centers must do to comply with the 19 program requirements and what documentation is required for showing compliance.

NWRPCA welcomes and regularly publishes white papers and articles submitted by members, partners and associates with subject matter expertise. The appearance of any guest publication in our Health Center News database represents the views of the author and does not constitute endorsement by NWRPCA of the stated opinions or perspectives, nor does it suggest endorsement of the contributor's products or services.

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