There is a list of 19 Health Center Program Requirements (PRs) that a community health center (CHC) must
meet during an Operational Site Visit (OSV). The purpose of an OSV is to verify compliance with the requirements. Two of the requirements that cause trouble for many health centers is PR #2 Required & Additional Services and PR #16 Scope of Project both of which involve services you provide through contract or formal written referral agreements. Annually you should schedule a time to look over and update your contracts to ensure that they meet program requirements.
The OSV reviewer is going to look at your scope of services document (Form 5A) to see which service you provide by contract or formal written agreement. Then the reviewer will want to review those contracts and referral agreements to see if they meet program requirements.
Getting your contracts in order for an Operational Site Visit
Review existing contracts:
Start by looking at Form 5A which you can find in the Electronic Handbook (EHB). Look at the contracts and formal referral agreements you have for services with other health care entities listed in Column II and Column III of Form 5A.
If you’ve marked a service in Column II, make sure that there is a formal written agreement (ex., memorandum of understanding (MOU), Memorandum of agreement (MOA) or contract) in place between your health center and outside organization/provider. The agreement should answer:
- How the service will be documented in the health center’s patient record
- How the health center will pay and/or bill for the service
- How the health center’s policies and/or procedures will apply
- The manner by which the referral will be made and managed
- The process for referring patients back to the center for appropriate follow-up care
If you’ve marked a service in Column III, an MOU, MOA or formal agreement must at a minimum describe the manner by which the referral will be made and managed and the process for referring patients back to the center for appropriate follow-up care. (While you’re reviewing your written formal referral agreements, it’s not a bad idea to take a look at your tracking and referral policy and procedures to make sure they reflect what you actually do and what you describe in your agreements.)
- Does the agency offer a sliding scale discount?
According to HRSA PIN 2014-02, sliding fee discounts must apply to all services within a health center’s approved scope of project for which there is an established charge. This rule applies regardless of whether it is a required or additional service type or the way in which the service is delivered. It’s your responsibility to ensure that discounts are offered by any referral providers for services listed in Column III.
Further questions for all services through an outside provider ask the following questions:
- Does the contract state how the service will be documented in your patient health record?
- Does it state how the you will pay and/or bill for the service?
- Does it state how your health center’s policies and procedures will apply?
- Do the agreements clearly clarify continuity of care arrangements? Do they describe the manner by which the referral will be made and managed?
- Do they describe how your patient will return to you for follow-up care?
- Is the service available equally to all health center patients? The referred service must be available equally, but not necessarily through the same referral provider.
If the health center serves patients with limited English proficiency (LEP)2 or with disabilities, has the health center taken reasonable steps to provide meaningful access to their services (Required and Additional) for such patients? Specifically:
- Are interpretation/translation service(s) provided that are appropriate and timely for the size/needs of the LEP health center patient population (e.g., bilingual providers, onsite interpreter, language telephone line)?
- Are auxiliary aids and services readily available and responsive to the needs of patients with disabilities (e.g., sign language interpreters, TTY lines)?
- Are 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) provided to patients in the appropriate languages, literacy levels, and/or alternative formats (for patients with disabilities), and in a timely manner?
- Are patients made aware of these resources?
Make sure nothing has expired and that you are getting the deliverables you’ve contracted for. Document in a log that your contracts have been reviewed and note any amendments.
Finally, if your contracting or referral arrangements have changed, do you need to do a change in scope?
How can Health Center Solutions help to prepare your CHC for an OSV?
At Health Center Solutions we are dedicated to helping community health centers. We can help your center get organized and prepare for a successful operational site visit. Many of our clients hire us to do a mock OSV to identify any weak spots and prepare them for the real event. Health Center Solutions’ dedicated professionals are focused on providing outcome-focused, customer-driven solutions. To schedule a meeting, a mock visit or to request more information about our solutions, please contact us today!