BPHC Publishes New PAL on 2012 FTCA Application Process
The Bureau of Primary Health Care has published Program Assistance Letter (PAL) 2011-05 Calendar Year 2012 Requirements for Federal Tort Claims Act (FTCA) Medical Malpractice Coverage for Health Centers. This PAL outlines the procedures that health centers must follow in applying to be deemed for calendar year 2012. Currently deemed health centers must submit their applications via the Electronic Handbook (EHB) by July 6, 2011. The EHB will be ready to accept applications as of June 1, 2011. Health centers that are not deemed may submit their initial deeming application at any time.
The PAL describes a number of expanded requirements over past applications and health centers should take care to make certain they have provided all the required supporting information with their applications. BPHC will provide technical assistance on the application process in a call on June 1, 2011. PAL 2011-15 is available in our FTCA Resource Center or at the BPHC website.
BPHC Uniform Data System (UDS) Manual - Reporting Instructions for Section 330 Grantees
BPHC Uniform Data System (UDS) Manual Reporting Instructions for Section 330 Grantees Calendar Year 2012
CMS Finalizes Provider Screening Rules
Last week we informed you about a forthcoming rule by the Centers for Medicare and Medicaid Services (CMS) implementing provisions of the Affordable Care Act (ACA) that strengthen provider and supplier screening provisions for participation in the Medicare, Medicaid, and Children's Health Insurance Program (CHIP). This week the rule was published in final form by the federal government. The final rule may be downloaded here. Silver Level and higher subscribers also can access the rule in our e-Library.
In general, CMS will apply an increasing level of screening based on the level of risk it has associated with different provider and supplier types. Under the rule, CMS assigned all providers and suppliers into three groups: (1) “limited risk” (2) “moderate risk” and (3) “high risk”. Notably, federally qualified health centers were assigned to the limited risk category. Although limited risk providers will have enrollment requirements, license, and database verifications, they will be spared the unscheduled site visits and criminal history background checks.
Additional analysis of the rule will be described in the forthcoming issue of Compliance Connection, available soon at HealthCenterCompliance.com.
New FTCA Publication: From time to time, we will alert you to new publications issued by federal agencies. This week we wish to highlight a recently issued FTCA resource by the Bureau of Primary Health Care (BPHC). On January 3, 2011, the BPHC issued the Federal Tort Claims Act (FTCA) Health Center Manual. The new Manual, published as a Policy Information Notice (PIN), consolidates previously published FTCA PINs and Program Assistance Letters (PALs). The publication may be downloaded here and is available in our e-Library and at the FTCA Resource Center.
FTCA Application Resources Now Available
With CY14 FTCA redeeming applications due to HRSA by Friday, May 3rd, HealthCenterCompliance.com reminds subscribers about the following FTCA-related resources which are now available (based on subscription level):
FTCA E-briefings for FTCA and All-Star Subscribers:
• Answering the prior claims history question: Additional information added on April 9th.
• Lessons learned and application changes: Updated for the CY14 deeming application cycle.
• Credentialing and privileging: A key to quality and risk management
Compliance Connection articles for All-Star, Gold, Silver and Bronze Subscribers:
• Four suggestions to writing effective policies and procedures
• FTCA coverage and the supervision of non-health center personnel
Toolkit Subscribers: In Volume 2: Health Center Risks under "Clinical":
• Intro Guidance: Credentialing & Privileging
• Sample Policy & Procedure: Credentialing & Privileging
ALL Subscribers, including Alerts & Announcements Subscribers:
• FTCA CY14 PAL 2013-05
• HRSA CY14 FTCA Technical Assistance Webcasts: Quick link with schedule
For more information or for assistance in completing your deeming application, please email Martin Bree, Esq., at email@example.com, or Molly Evans, Esq., at firstname.lastname@example.org, or call toll-free at 1-855-200-FTCA.
FTCA Redeeming Applications Due May 3, 2013
HRSA recently published Program Assistance Letter 2013-05 Calendar Year 2014 Requirements for Federal Tort Claims Act (FTCA) Medical Malpractice Coverage for Health Centers. Applications for redeeming are due to HRSA via the Electronic Handbook no later than May 3, 2013. Failure to submit a redeeming application in a timely manner will likely result in loss of FTCA coverage. Applications may be submitted beginning March 28, 2013.
While the statutory requirements for deeming remain the same, the application includes the following requirements this year:
• Name and contact information for the Board Chair must be included in the contact information section of the application.
A copy of PAL 2013-05 is available here.
HRSA Administrator Announces Department-wide Program Integrity Initiative
The Administrator of the Health Resources and Services Administration (HRSA), Dr. Mary Wakefield, recently sent a letter to all HRSA grantees announcing a departmental-wide Program Integrity Initiative (PII).
The PII, established by the U.S. Department of Health & Human Services (HHS), was created as a response to the President’s challenge to the agencies to eliminate improper payments and reduce the risk of waste, fraud, and abuse. The PII is designed to target the greatest risks of fraud, waste, and abuse; reduce those risks by enhancing existing program integrity operations; share new and best program integrity practices; and measure the results of HHS’ efforts toward strengthening program integrity.
To monitor HRSA grantees (such as federally-funded health centers), HRSA plans to expand the use of site visits and review of financial information. In addition, the agency seeks to provide technical assistance, resolve problems, and ensure adherence and compliance with program expectations.
For tools and resources that can assist your health center’s compliance with legal requirements and program expectations, visit HealthCenterCompliance.com.
HRSA Announces Upcoming Changes for Health Center Grantees
During a recent webcast, HRSA announced that the project period for health center grantees will change from five to three year starting in 2014. During this project period, compliance will be assessed through the Service Area Competition (SAC) application and through the operational site visit. An operational site visit will occur about half-way through the project period, approximately 18 months after the SAC. Operational site visits will then occur on a three year cycle. Health centers will submit a streamlined Budget Period Progress Report after year one and year two.
HRSA also announced that it expects to issue the following Program Information Notices (PINs) in the coming months: Total Budget PIN (in effect with the 2014 award cycle), Sliding Fee Scale Final PIN and QI/QA Draft PIN.
The webcast included a review of FY 2013 spending for the health center program, including the announcement that current base funding will be maintained and health centers will be made whole with their June payments. Beginning in August, $48 million will be awarded as a base adjustment to support health centers with the increased cost of providing care and to sustain quality improvements, including patient centered medical home designation efforts. HRSA anticipates awarding 25 New Access Point applications in September. Unfunded New Access Point applications will remain viable for one year should additional resources become available.
To view the HRSA webcast, click HERE.
For questions related to Section 330 program requirements or HRSA policies, contact Marcie Zakheim, Esq., at email@example.com.
HRSA Health Center Program Requirements
HRSA Presentation on Health Center Program Requirements