SlideShare a Scribd company logo
1 of 33
Download to read offline
www.compliantfqhc.com
Continuous Compliance Series- It’s not JUST an
OSV Prep
COMPLIATRIC WEBINAR SERIES
Presented by : Jennifer Genua-McDaniel
jgenua@genuaconsulting.com
This presentation is not endorsed by Management Strategists Consulting
Group (MSCG)
This presentation is not endorsed by Health Resources Services
Administration (HRSA) or Bureau of Primary Health Care (BPHC)
Not employed by MSCG or BPHC
Independent consultant who is contracted to do Operational Site Visits
(OSV)s and Technical Assistance (TA)
Not intended to provide legal advice
For specific questions, please consult your HRSA Point of Contact
Updates to the Site Visit
Protocol (SVP)
Review clarification to the
elements
Methods to maintain
continuous compliance
Requirements are the foundation
not the ceiling
Best practices for health centers
Improving excellence
Using the requirements in every
day practice
Contracts and Subawards
 Please do the following:
◦ Review the Compliance Manual (Chapter 12
Contracts/Subawards) and footnotes
 https://bphc.hrsa.gov/compliance/compliance-manual/chapter12
 Definition of “simplified acquisition threshold” [small
purchase methods] and what those thresholds are based on
48 CFR subpart 2.1 and 41 U.S.C. 1907
◦ FQHC Look-Alikes:
 Does not apply BUT if received any HRSA funding during the
pandemic this may apply (Covid Cares $$). This includes
Chapter 13- Conflict of Interest
 If you’re having a site visit, please check with HRSA Point of
Contact
◦ Review the HRSA Sampling Guide
 https://bphc.hrsa.gov/programrequirements/svprotocol/resource-guide
 Element A: Procurement Procedures
◦ Are they written?
 Describe how a health center makes purchases of
supplies, equipment, etc.
 Any procurement directly attributed to the federal
award conducted in a manner providing full and open
competition, consistent with federal cost principles
 45 CFR Part 75, Subpart E: Cost Principles
Also includes non-
competitive
proposals including
sole source
(45 CFR 75.329(f))
 Element B: Records of Procurement Actions
◦ Review of (5) five contracts AND supporting
documentation that use federal award funds
https://bphc.hrsa.gov/compliance/site-visits/sampling-review#contracts
 Element B: Records of Procurement Actions
◦ Based on documentation:
 Rationale for procurement method
 Selection of contract type (sole source, competition, etc.)
 Contractor selection or rejection
 Basis for contract price
◦ Comply with 45 CFR 75.328
 Open and fair competition and if not:
 Item is only available from a single source
 Public Emergency
 Non-competitive is authorized by HRSA
 Competition is determined to be inadequate after getting a few sources
 Element C: Retention of Final Contracts
◦ Is the health center able to provide the final
executed contract?
 Retain financial records, supporting documents,
statistical records, and all other records pertinent to
the Health Center Program for a period of three years
from the date of the submission of the final
expenditures report to HHS
 Element D: Contractor Reporting
◦ How do you oversee contractor performance?
 Examples: Performance goals, invoices/payments
reconciled, UDS submission
 Element F: Required Contract Provisions
◦ Contracts that support HRSA approved scope of
project
 Includes Form 5A, Column II contracts
Element E: HRSA Approval for
Contracting Substantive
Programmatic Work
•HRSA approved (it will be in
Notice of Funding Award
[NOFA])
•A single entity for the majority
of health care providers
•Ex. Pass through entity, all
employees are leased except
for the CEO
Elements G-J: Subrecipient
Monitoring
•Subrecipient supports the
Health Center’s scope of
project
•Must comply with ALL HRSA
Program Requirements
•Health Center must monitor
the subrecipient and keep
records
 Contracts (based on the HRSA requirements)
✓List of the entities involved
 Who is the contract with?
✓List of services to be provided
 Description of services
✓How will the health center pay for the services
 Invoiced monthly, quarterly, etc.
✓How will the service be documented in the patient
record?
 Will the contractor send a treatment plan? Will it be
documented in the health center’s health record?
✓Assurances of Credentialing and Privileging
 “Provider agrees to provide Health Center with assurances that,
during the term of this contract agreement, it, and as
applicable, its individual healthcare practitioners furnishing the
services to health center patients are and will remain: 1) duly
licensed, certified and/or otherwise qualified to provide services
hereunder, with appropriate training, education and experience
in their particular field; 2) appropriately credentialed and
privileged; and 3) eligible to participate in federal health care
programs including Medicaid and Medicare”
✓Sliding Fee Discount Program (SFDP)
 “Discounts are provided in a manner that meets all Health
Center Program requirements, ex. health center applies its own
sliding fee discount to amounts owed by eligible patients;
contract contains specific sliding fee provisions; contracted
services are provided by another health center which applies a
sliding fee discount that meets structural requirements”
✓Monitoring contract performance
 Ensuring that the contract is being carried out
 What documents will be requested?
 What happens if there is an issue with the service provided?
✓Data reporting expectations and intervals
 Will data will be provided to know the contract is going well?
Are you going to use invoices and cross reference payment
as a reporting expectation? What about treatment plans
received back in a certain period?
✓Provisions for record retention and access, audit and
property management
 Who owns the record? How long do you keep medical
records? What about audits and access to records?
 How to keep this requirement compliant
◦ Create a checklist of HRSA requirements for
contracts
 Paper or electronic tracking of all contracts
 Ensure contracts are not expired, or monitor expiry
date by using a system or a platform
◦ Use the HRSA Center Self-Assessment Worksheet
for Form 5A: Services Provided
◦ https://bphc.hrsa.gov/sites/default/files/bphc/programrequirements/scope/fo
rm-5a-self-assessment-review.pdf
◦
 How to keep this requirement compliant
◦ Work with legal counsel for standard contract
templates to ensure other contractual language
◦ Create addendums, if needed, for contracts (Quest,
LabCorp, etc.)
 If addendums are added, provide the entire contract
and addendums for review during site visits
◦ Keep contracts in one place
Contracts help health centers provide services we may
not be able to offer in house
Ensure they protect the health center and provide
clarity to roles and responsibilities
Can help to avoid expensive and potential risk and
disputes
 Source: Instagram
Conflict of Interest
 Element A: Standards of Conduct
◦ Do WRITTEN standards of conduct apply for the
selection, award and administration of contracts
that at a minimum apply to its procurement paid for
in whole or in part by the federal award?
 Element A: Standards of Conduct
 Element B: Standards for Organizational
Conflicts of Interests
◦ Do the standards prevent or mitigate any identified
or perceived conflicts of interest?
◦ Does a health center’s audit (A133) identify any
perceived or identified conflict of interest?
 (Review the two (2) most recent audits and
management letters)
 Element C: Dissemination of Standards of
Conduct
◦ How does your health center inform employees,
officers, board members and agents of the conflict-
of-interest standards?
 Element D: Adherence to Standards of
Conduct
◦ Reviewing of contracts from Chapter 12 (Contracts)
on procurement process
◦ Reading Board of Directors meeting minutes
◦ Is there documentation of a perceived or apparent
conflict in the past three (3) years?
 If so, what were the steps and what do the disclosures
state?
 Considerations:
◦ Polices/Standard of Conduct must be reflective of
current operational practices
◦ If your bylaws only address Conflict of Interest for board
and officers, ensure that documentation is also provided
for employees and agents of the health center
◦ A conflict of interest does not mean that a health center
is out of compliance
 Follow the policies and procedures that your health center
has
 Declare and document the conflict
 Be mindful of conflicts in the organization
◦ Sometimes it’s difficult in smaller rural areas
◦ Certain companies may have an
expertise/equipment that a health center needs
◦ Have employees sign conflict of interest statements
 Keep in Human Resource (HR) files
 A133 annual audits require Conflict of
Interest Statements signed by the Board and
Senior Team
 https://bphc.hrsa.gov/programrequirements/compliancemanual/index.
html
 Health Center Self-Assessment Worksheet for Form 5A: Services
Provided (hrsa.gov)
 https://www.healthcenterinfo.org/
 https://bphc.hrsa.gov/programrequirements/svprotocol
 MOU-vs-Contracts_FINAL_20120117.pdf (changelabsolutions.org)
 Jennifer Genua-McDaniel, BA (Hons), CHCEF
◦ Genua Consulting, LLC
◦ jgenua@genuaconsulting.com

More Related Content

What's hot

Electronic Health Records (ITCS404: IT for Healthcare Services)
Electronic Health Records (ITCS404: IT for Healthcare Services)Electronic Health Records (ITCS404: IT for Healthcare Services)
Electronic Health Records (ITCS404: IT for Healthcare Services)Nawanan Theera-Ampornpunt
 
Us Health System Ppt
Us Health System PptUs Health System Ppt
Us Health System Pptasadhu86
 
1-2 An Introduction to Clinical Informatics: History, Domains, and Careers
1-2 An Introduction to Clinical Informatics: History, Domains, and Careers1-2 An Introduction to Clinical Informatics: History, Domains, and Careers
1-2 An Introduction to Clinical Informatics: History, Domains, and CareersCorinn Pope
 
Kano State Health Profile - Nigeria
Kano State Health Profile - NigeriaKano State Health Profile - Nigeria
Kano State Health Profile - NigeriaHFG Project
 
The Global Food Security Index and Inplications for South Africa by Prof. She...
The Global Food Security Index and Inplications for South Africa by Prof. She...The Global Food Security Index and Inplications for South Africa by Prof. She...
The Global Food Security Index and Inplications for South Africa by Prof. She...Malabo-Montpellier-Panel
 
2023 Compliatric Webinar Series - 340B Recertification and Audit Changes
2023 Compliatric Webinar Series - 340B Recertification and Audit Changes2023 Compliatric Webinar Series - 340B Recertification and Audit Changes
2023 Compliatric Webinar Series - 340B Recertification and Audit ChangesCompliatric Where Compliance Happens
 
Cuba health economy
Cuba health economyCuba health economy
Cuba health economyNazmaShaikh4
 
Case Study of Yankee Stadium | Information and emerging technology
Case Study of Yankee Stadium | Information and emerging technologyCase Study of Yankee Stadium | Information and emerging technology
Case Study of Yankee Stadium | Information and emerging technologyBibesh Manandhar
 
The importance of patient privacy
The importance of patient privacyThe importance of patient privacy
The importance of patient privacytbella
 
The Biggest Barriers to Healthcare Interoperability
The Biggest Barriers to Healthcare InteroperabilityThe Biggest Barriers to Healthcare Interoperability
The Biggest Barriers to Healthcare InteroperabilityHealth Catalyst
 
Establishing a Professional Social Media Presence
Establishing a Professional Social Media Presence Establishing a Professional Social Media Presence
Establishing a Professional Social Media Presence Iris Thiele Isip-Tan
 
Healthcare Industry Highlight: Revenue Cycle Management
Healthcare Industry Highlight: Revenue Cycle ManagementHealthcare Industry Highlight: Revenue Cycle Management
Healthcare Industry Highlight: Revenue Cycle ManagementCascadia_Capital
 
340 b presentation 5.31.13
340 b presentation 5.31.13340 b presentation 5.31.13
340 b presentation 5.31.13Michol Bobb
 
Healthcare Billing and Reimbursement: Starting from Scratch
Healthcare Billing and Reimbursement: Starting from ScratchHealthcare Billing and Reimbursement: Starting from Scratch
Healthcare Billing and Reimbursement: Starting from ScratchDale Sanders
 
Revenue Cycle Management
Revenue Cycle ManagementRevenue Cycle Management
Revenue Cycle ManagementDivyang Bhatt
 
CMS 1500 Instructions
CMS 1500 InstructionsCMS 1500 Instructions
CMS 1500 InstructionsKarna *
 
Healthcare system in taiwan
Healthcare system in taiwanHealthcare system in taiwan
Healthcare system in taiwan翰泓 李
 
Coding for Mental Health in Today's Environment
Coding for Mental Health in Today's EnvironmentCoding for Mental Health in Today's Environment
Coding for Mental Health in Today's EnvironmentPYA, P.C.
 
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�Quarles & Brady
 

What's hot (20)

Electronic Health Records (ITCS404: IT for Healthcare Services)
Electronic Health Records (ITCS404: IT for Healthcare Services)Electronic Health Records (ITCS404: IT for Healthcare Services)
Electronic Health Records (ITCS404: IT for Healthcare Services)
 
Us Health System Ppt
Us Health System PptUs Health System Ppt
Us Health System Ppt
 
1-2 An Introduction to Clinical Informatics: History, Domains, and Careers
1-2 An Introduction to Clinical Informatics: History, Domains, and Careers1-2 An Introduction to Clinical Informatics: History, Domains, and Careers
1-2 An Introduction to Clinical Informatics: History, Domains, and Careers
 
Kano State Health Profile - Nigeria
Kano State Health Profile - NigeriaKano State Health Profile - Nigeria
Kano State Health Profile - Nigeria
 
The Global Food Security Index and Inplications for South Africa by Prof. She...
The Global Food Security Index and Inplications for South Africa by Prof. She...The Global Food Security Index and Inplications for South Africa by Prof. She...
The Global Food Security Index and Inplications for South Africa by Prof. She...
 
2023 Compliatric Webinar Series - 340B Recertification and Audit Changes
2023 Compliatric Webinar Series - 340B Recertification and Audit Changes2023 Compliatric Webinar Series - 340B Recertification and Audit Changes
2023 Compliatric Webinar Series - 340B Recertification and Audit Changes
 
Cuba health economy
Cuba health economyCuba health economy
Cuba health economy
 
Case Study of Yankee Stadium | Information and emerging technology
Case Study of Yankee Stadium | Information and emerging technologyCase Study of Yankee Stadium | Information and emerging technology
Case Study of Yankee Stadium | Information and emerging technology
 
2022 Compliatric Continuous Compliance Series - Chapter 19.pdf
2022 Compliatric Continuous Compliance Series - Chapter 19.pdf2022 Compliatric Continuous Compliance Series - Chapter 19.pdf
2022 Compliatric Continuous Compliance Series - Chapter 19.pdf
 
The importance of patient privacy
The importance of patient privacyThe importance of patient privacy
The importance of patient privacy
 
The Biggest Barriers to Healthcare Interoperability
The Biggest Barriers to Healthcare InteroperabilityThe Biggest Barriers to Healthcare Interoperability
The Biggest Barriers to Healthcare Interoperability
 
Establishing a Professional Social Media Presence
Establishing a Professional Social Media Presence Establishing a Professional Social Media Presence
Establishing a Professional Social Media Presence
 
Healthcare Industry Highlight: Revenue Cycle Management
Healthcare Industry Highlight: Revenue Cycle ManagementHealthcare Industry Highlight: Revenue Cycle Management
Healthcare Industry Highlight: Revenue Cycle Management
 
340 b presentation 5.31.13
340 b presentation 5.31.13340 b presentation 5.31.13
340 b presentation 5.31.13
 
Healthcare Billing and Reimbursement: Starting from Scratch
Healthcare Billing and Reimbursement: Starting from ScratchHealthcare Billing and Reimbursement: Starting from Scratch
Healthcare Billing and Reimbursement: Starting from Scratch
 
Revenue Cycle Management
Revenue Cycle ManagementRevenue Cycle Management
Revenue Cycle Management
 
CMS 1500 Instructions
CMS 1500 InstructionsCMS 1500 Instructions
CMS 1500 Instructions
 
Healthcare system in taiwan
Healthcare system in taiwanHealthcare system in taiwan
Healthcare system in taiwan
 
Coding for Mental Health in Today's Environment
Coding for Mental Health in Today's EnvironmentCoding for Mental Health in Today's Environment
Coding for Mental Health in Today's Environment
 
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�
340B Discount Drug Program: Updates and Changes Affecting Contract Pharmacies�
 

Similar to 2022 Compliatric Continuous Compliance Series - Chapter 12 and 13.pdf

Compliatric continuous compliance series chapter 12 and chapter 13
Compliatric continuous compliance series  chapter 12 and chapter 13Compliatric continuous compliance series  chapter 12 and chapter 13
Compliatric continuous compliance series chapter 12 and chapter 13Compliatric Where Compliance Happens
 
Compliatric continuous compliance series chapters 12 and 13
Compliatric continuous compliance series  chapters 12 and 13Compliatric continuous compliance series  chapters 12 and 13
Compliatric continuous compliance series chapters 12 and 13Compliatric
 
Contracts and mo us what to use and when
Contracts and mo us what to use and whenContracts and mo us what to use and when
Contracts and mo us what to use and whenCompliatric
 
Discusses the resources needed to ensure billing and coding compliance update...
Discusses the resources needed to ensure billing and coding compliance update...Discusses the resources needed to ensure billing and coding compliance update...
Discusses the resources needed to ensure billing and coding compliance update...intel-writers.com
 
Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08Compliatric
 
Reporting quality data to the board of directors
Reporting quality data to the board of directorsReporting quality data to the board of directors
Reporting quality data to the board of directorsCompliatric
 
Auditing and Monitoring-Checklist.pdf
Auditing and Monitoring-Checklist.pdfAuditing and Monitoring-Checklist.pdf
Auditing and Monitoring-Checklist.pdfMANORANJAN891810
 
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!mwright1
 
Auditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerAuditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerMD Ranger, Inc.
 
Developing a Practice Compliance Plan
Developing a Practice Compliance PlanDeveloping a Practice Compliance Plan
Developing a Practice Compliance Planshelvan1967
 
Billing compliance results management-2013
Billing compliance results management-2013Billing compliance results management-2013
Billing compliance results management-2013nbattah
 
Audit Smart: A Best Practices Webinar for Physician Contracting
Audit Smart: A Best Practices Webinar for Physician Contracting Audit Smart: A Best Practices Webinar for Physician Contracting
Audit Smart: A Best Practices Webinar for Physician Contracting MD Ranger, Inc.
 
3 proposing client support solutions
3 proposing client support solutions3 proposing client support solutions
3 proposing client support solutionshapy
 
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdfCompliatric Where Compliance Happens
 
Navigating Physician Contracts with Ease
Navigating Physician Contracts with EaseNavigating Physician Contracts with Ease
Navigating Physician Contracts with EaseMD Ranger, Inc.
 

Similar to 2022 Compliatric Continuous Compliance Series - Chapter 12 and 13.pdf (20)

Compliatric continuous compliance series chapter 12 and chapter 13
Compliatric continuous compliance series  chapter 12 and chapter 13Compliatric continuous compliance series  chapter 12 and chapter 13
Compliatric continuous compliance series chapter 12 and chapter 13
 
Compliatric continuous compliance series chapters 12 and 13
Compliatric continuous compliance series  chapters 12 and 13Compliatric continuous compliance series  chapters 12 and 13
Compliatric continuous compliance series chapters 12 and 13
 
Contracts and MOUs what to use and when
Contracts and MOUs what to use and whenContracts and MOUs what to use and when
Contracts and MOUs what to use and when
 
Contracts and mo us what to use and when
Contracts and mo us what to use and whenContracts and mo us what to use and when
Contracts and mo us what to use and when
 
OIG UR doc guidelines presentation
OIG UR doc guidelines   presentationOIG UR doc guidelines   presentation
OIG UR doc guidelines presentation
 
Discusses the resources needed to ensure billing and coding compliance update...
Discusses the resources needed to ensure billing and coding compliance update...Discusses the resources needed to ensure billing and coding compliance update...
Discusses the resources needed to ensure billing and coding compliance update...
 
Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08
 
Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08Fy 2021 hrsa operational site visit updates 2021.09.08
Fy 2021 hrsa operational site visit updates 2021.09.08
 
Reporting quality data to the board of directors
Reporting quality data to the board of directorsReporting quality data to the board of directors
Reporting quality data to the board of directors
 
Reporting quality data to the board of directors
Reporting quality data to the board of directorsReporting quality data to the board of directors
Reporting quality data to the board of directors
 
Auditing and Monitoring-Checklist.pdf
Auditing and Monitoring-Checklist.pdfAuditing and Monitoring-Checklist.pdf
Auditing and Monitoring-Checklist.pdf
 
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!
Having a Prosperous New Year with Your CRO: The Gift of a Great Contract!
 
Auditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerAuditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD Ranger
 
Developing a Practice Compliance Plan
Developing a Practice Compliance PlanDeveloping a Practice Compliance Plan
Developing a Practice Compliance Plan
 
Billing compliance results management-2013
Billing compliance results management-2013Billing compliance results management-2013
Billing compliance results management-2013
 
Audit Smart: A Best Practices Webinar for Physician Contracting
Audit Smart: A Best Practices Webinar for Physician Contracting Audit Smart: A Best Practices Webinar for Physician Contracting
Audit Smart: A Best Practices Webinar for Physician Contracting
 
3 proposing client support solutions
3 proposing client support solutions3 proposing client support solutions
3 proposing client support solutions
 
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf
2022 Compliatric Continuous Compliance Series - Chapter 10 and 21.pdf
 
Navigating Physician Contracts with Ease
Navigating Physician Contracts with EaseNavigating Physician Contracts with Ease
Navigating Physician Contracts with Ease
 
Compliatric Deep Dive Into HRSA Site Visit Protocol Updates
Compliatric Deep Dive Into HRSA Site Visit Protocol UpdatesCompliatric Deep Dive Into HRSA Site Visit Protocol Updates
Compliatric Deep Dive Into HRSA Site Visit Protocol Updates
 

More from Compliatric Where Compliance Happens

2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...Compliatric Where Compliance Happens
 
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdfCompliatric Where Compliance Happens
 
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...Compliatric Where Compliance Happens
 
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdfCompliatric Where Compliance Happens
 
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdfCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...Compliatric Where Compliance Happens
 
Contracts and Memorandums of Understanding - Requirements and Responsibilities
Contracts and Memorandums of Understanding - Requirements and ResponsibilitiesContracts and Memorandums of Understanding - Requirements and Responsibilities
Contracts and Memorandums of Understanding - Requirements and ResponsibilitiesCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdfCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdfCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdfCompliatric Where Compliance Happens
 
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdf
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdfCompliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdf
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdfCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...Compliatric Where Compliance Happens
 
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptxCompliatric Where Compliance Happens
 
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdfCompliatric Where Compliance Happens
 

More from Compliatric Where Compliance Happens (20)

2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion April 202...
 
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
 
2024 Compliatric Webinar Series - Protecting LGBTQ Patients.pdf
2024 Compliatric Webinar Series - Protecting LGBTQ Patients.pdf2024 Compliatric Webinar Series - Protecting LGBTQ Patients.pdf
2024 Compliatric Webinar Series - Protecting LGBTQ Patients.pdf
 
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...
2024 Compliatric Webinar Series - Next-Gen Compliance- Leveraging OIG's Recen...
 
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf
2024 Compliatric Webinar Series - Components of a Needs Assessment.pdf
 
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf
2024 Compliatric Webinar Series - OSV Overview and Panel Discussion.pdf
 
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...
2023 Compliatric Webinar Series - Unveiling the Blueprint_ The Components of ...
 
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...
2023 Compliatric Webinar Series - Contracts and Memorandums of Understanding ...
 
Contracts and Memorandums of Understanding - Requirements and Responsibilities
Contracts and Memorandums of Understanding - Requirements and ResponsibilitiesContracts and Memorandums of Understanding - Requirements and Responsibilities
Contracts and Memorandums of Understanding - Requirements and Responsibilities
 
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...
2023 Compliatric Webinar Series - Making the Most out of the Sliding Fee Prog...
 
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...
2023 Compliatric Webinar Series - Developing Strong Board and CEO Relationshi...
 
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf
2023 Compliatric Webinar Series - Overview of CARF Accreditation.pdf
 
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf
2023 Compliatric Webinar Series - Are You Ready for an OSHA Inspection.pdf
 
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...
2023 Compliatric Webinar Series - Good Faith Estimates_Don't Let the No Surpr...
 
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...
2023 Compliatric Webinar Series - Your Accreditation Journey - Challenges Alo...
 
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf
2023 Compliatric Webinar Series - Active Shooter Training and Exercises.pdf
 
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdf
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdfCompliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdf
Compliatric Webinar Your Accreditation Journey Best Path Forward 7.25.2023.pdf
 
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...
2023 Compliatric Webinar Series - Developing a Pathway for Promotion & Leader...
 
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx
2023 Compliatric Webinar Series Strategic Planning Webinar 06_20_2023.pptx
 
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf
2023 Compliatric Webinar Series - The Basics of Disaster Preparedness.pdf
 

Recently uploaded

Test bank criminal behavior a psychological approach 12e bartol.pdf
Test bank criminal behavior a psychological approach 12e bartol.pdfTest bank criminal behavior a psychological approach 12e bartol.pdf
Test bank criminal behavior a psychological approach 12e bartol.pdfmarcuskenyatta275
 
Weighing the Risks and Benefits: Angioplasty at Gokuldas Hospitals
Weighing the Risks and Benefits: Angioplasty at Gokuldas HospitalsWeighing the Risks and Benefits: Angioplasty at Gokuldas Hospitals
Weighing the Risks and Benefits: Angioplasty at Gokuldas HospitalsGokuldas Hospital
 
EHR Market Growth is The Boom Over - Jasper Colin
EHR Market Growth is The Boom Over - Jasper ColinEHR Market Growth is The Boom Over - Jasper Colin
EHR Market Growth is The Boom Over - Jasper ColinJasper Colin
 
Leading big change: what does it take to deliver at large scale?
Leading big change: what does it take to deliver at large scale?Leading big change: what does it take to deliver at large scale?
Leading big change: what does it take to deliver at large scale?HelenBevan4
 
Nursing Diagnosis: The Second Phase of The Nursing Process
Nursing Diagnosis: The Second Phase of The Nursing ProcessNursing Diagnosis: The Second Phase of The Nursing Process
Nursing Diagnosis: The Second Phase of The Nursing ProcessRommel Luis III Israel
 
2024 Medicare AEP Shopping Experience: Consumer Insight Survey
2024 Medicare AEP Shopping Experience: Consumer Insight Survey2024 Medicare AEP Shopping Experience: Consumer Insight Survey
2024 Medicare AEP Shopping Experience: Consumer Insight SurveyMedia Logic
 
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWAT
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWATDISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWAT
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWATNehaKewat
 
Disseminated Intravascular Coagulation.ppt
Disseminated Intravascular Coagulation.pptDisseminated Intravascular Coagulation.ppt
Disseminated Intravascular Coagulation.pptSameer Jain
 
Enhancing Health Through Personalized Nutrition
Enhancing Health Through Personalized NutritionEnhancing Health Through Personalized Nutrition
Enhancing Health Through Personalized NutritionNeighborhood Trainer
 
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEM
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEMLABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEM
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEMRommel Luis III Israel
 
AMIKINHAL Presentation Journal Club (3).pptx
AMIKINHAL Presentation Journal Club (3).pptxAMIKINHAL Presentation Journal Club (3).pptx
AMIKINHAL Presentation Journal Club (3).pptxDileepRedemption
 
CASE STUDY ON CHRONIC KIDNEY DISEASE.pptx
CASE  STUDY ON CHRONIC KIDNEY DISEASE.pptxCASE  STUDY ON CHRONIC KIDNEY DISEASE.pptx
CASE STUDY ON CHRONIC KIDNEY DISEASE.pptxdrsriram2001
 
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are Heard
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are HeardAdvance Directives and Advance Care Planning: Ensuring Patient Voices Are Heard
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are HeardVITASAuthor
 
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWAT
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWATBURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWAT
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWATNehaKewat
 
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptx
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptxLipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptx
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptxRajendra Dev Bhatt
 
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdf
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdfPreventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdf
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdfAditiAlishetty
 
Your Radiotherapy Destination Gokuldas Hospital.
Your Radiotherapy Destination Gokuldas Hospital.Your Radiotherapy Destination Gokuldas Hospital.
Your Radiotherapy Destination Gokuldas Hospital.Gokuldas Hospital
 
X-Ray Beam Restrictors/Beam Modifying devices.pptx
X-Ray Beam Restrictors/Beam Modifying devices.pptxX-Ray Beam Restrictors/Beam Modifying devices.pptx
X-Ray Beam Restrictors/Beam Modifying devices.pptxDr. Dheeraj Kumar
 
Immediate care of newborn, midwifery and obstetrical nursing
Immediate care of newborn, midwifery and obstetrical nursingImmediate care of newborn, midwifery and obstetrical nursing
Immediate care of newborn, midwifery and obstetrical nursingNursing education
 
Subconjunctival Haemorrhage,causes,treatment..pptx
Subconjunctival Haemorrhage,causes,treatment..pptxSubconjunctival Haemorrhage,causes,treatment..pptx
Subconjunctival Haemorrhage,causes,treatment..pptxvideosfildr
 

Recently uploaded (20)

Test bank criminal behavior a psychological approach 12e bartol.pdf
Test bank criminal behavior a psychological approach 12e bartol.pdfTest bank criminal behavior a psychological approach 12e bartol.pdf
Test bank criminal behavior a psychological approach 12e bartol.pdf
 
Weighing the Risks and Benefits: Angioplasty at Gokuldas Hospitals
Weighing the Risks and Benefits: Angioplasty at Gokuldas HospitalsWeighing the Risks and Benefits: Angioplasty at Gokuldas Hospitals
Weighing the Risks and Benefits: Angioplasty at Gokuldas Hospitals
 
EHR Market Growth is The Boom Over - Jasper Colin
EHR Market Growth is The Boom Over - Jasper ColinEHR Market Growth is The Boom Over - Jasper Colin
EHR Market Growth is The Boom Over - Jasper Colin
 
Leading big change: what does it take to deliver at large scale?
Leading big change: what does it take to deliver at large scale?Leading big change: what does it take to deliver at large scale?
Leading big change: what does it take to deliver at large scale?
 
Nursing Diagnosis: The Second Phase of The Nursing Process
Nursing Diagnosis: The Second Phase of The Nursing ProcessNursing Diagnosis: The Second Phase of The Nursing Process
Nursing Diagnosis: The Second Phase of The Nursing Process
 
2024 Medicare AEP Shopping Experience: Consumer Insight Survey
2024 Medicare AEP Shopping Experience: Consumer Insight Survey2024 Medicare AEP Shopping Experience: Consumer Insight Survey
2024 Medicare AEP Shopping Experience: Consumer Insight Survey
 
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWAT
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWATDISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWAT
DISASTER MANAGE-WPS Office-1.pptx PREPARED BY NEHA KEWAT
 
Disseminated Intravascular Coagulation.ppt
Disseminated Intravascular Coagulation.pptDisseminated Intravascular Coagulation.ppt
Disseminated Intravascular Coagulation.ppt
 
Enhancing Health Through Personalized Nutrition
Enhancing Health Through Personalized NutritionEnhancing Health Through Personalized Nutrition
Enhancing Health Through Personalized Nutrition
 
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEM
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEMLABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEM
LABORATORY PROCEDURES-ALTERATION IN THE ENDOCRINE SYSTEM
 
AMIKINHAL Presentation Journal Club (3).pptx
AMIKINHAL Presentation Journal Club (3).pptxAMIKINHAL Presentation Journal Club (3).pptx
AMIKINHAL Presentation Journal Club (3).pptx
 
CASE STUDY ON CHRONIC KIDNEY DISEASE.pptx
CASE  STUDY ON CHRONIC KIDNEY DISEASE.pptxCASE  STUDY ON CHRONIC KIDNEY DISEASE.pptx
CASE STUDY ON CHRONIC KIDNEY DISEASE.pptx
 
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are Heard
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are HeardAdvance Directives and Advance Care Planning: Ensuring Patient Voices Are Heard
Advance Directives and Advance Care Planning: Ensuring Patient Voices Are Heard
 
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWAT
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWATBURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWAT
BURNS AND ITS MANAGEMENT.pptx PREPARED BY NEHA KEWAT
 
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptx
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptxLipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptx
Lipid Profile test & Cardiac Markers for MBBS, Lab. Med. and Nursing.pptx
 
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdf
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdfPreventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdf
Preventing Common Nutritional Deficiencies In Poultry Flocks (PPT).pdf
 
Your Radiotherapy Destination Gokuldas Hospital.
Your Radiotherapy Destination Gokuldas Hospital.Your Radiotherapy Destination Gokuldas Hospital.
Your Radiotherapy Destination Gokuldas Hospital.
 
X-Ray Beam Restrictors/Beam Modifying devices.pptx
X-Ray Beam Restrictors/Beam Modifying devices.pptxX-Ray Beam Restrictors/Beam Modifying devices.pptx
X-Ray Beam Restrictors/Beam Modifying devices.pptx
 
Immediate care of newborn, midwifery and obstetrical nursing
Immediate care of newborn, midwifery and obstetrical nursingImmediate care of newborn, midwifery and obstetrical nursing
Immediate care of newborn, midwifery and obstetrical nursing
 
Subconjunctival Haemorrhage,causes,treatment..pptx
Subconjunctival Haemorrhage,causes,treatment..pptxSubconjunctival Haemorrhage,causes,treatment..pptx
Subconjunctival Haemorrhage,causes,treatment..pptx
 

2022 Compliatric Continuous Compliance Series - Chapter 12 and 13.pdf

  • 1. www.compliantfqhc.com Continuous Compliance Series- It’s not JUST an OSV Prep COMPLIATRIC WEBINAR SERIES Presented by : Jennifer Genua-McDaniel jgenua@genuaconsulting.com
  • 2.
  • 3.
  • 4. This presentation is not endorsed by Management Strategists Consulting Group (MSCG) This presentation is not endorsed by Health Resources Services Administration (HRSA) or Bureau of Primary Health Care (BPHC) Not employed by MSCG or BPHC Independent consultant who is contracted to do Operational Site Visits (OSV)s and Technical Assistance (TA) Not intended to provide legal advice For specific questions, please consult your HRSA Point of Contact
  • 5. Updates to the Site Visit Protocol (SVP) Review clarification to the elements Methods to maintain continuous compliance Requirements are the foundation not the ceiling Best practices for health centers Improving excellence Using the requirements in every day practice
  • 6.
  • 8.  Please do the following: ◦ Review the Compliance Manual (Chapter 12 Contracts/Subawards) and footnotes  https://bphc.hrsa.gov/compliance/compliance-manual/chapter12  Definition of “simplified acquisition threshold” [small purchase methods] and what those thresholds are based on 48 CFR subpart 2.1 and 41 U.S.C. 1907 ◦ FQHC Look-Alikes:  Does not apply BUT if received any HRSA funding during the pandemic this may apply (Covid Cares $$). This includes Chapter 13- Conflict of Interest  If you’re having a site visit, please check with HRSA Point of Contact ◦ Review the HRSA Sampling Guide  https://bphc.hrsa.gov/programrequirements/svprotocol/resource-guide
  • 9.  Element A: Procurement Procedures ◦ Are they written?  Describe how a health center makes purchases of supplies, equipment, etc.  Any procurement directly attributed to the federal award conducted in a manner providing full and open competition, consistent with federal cost principles  45 CFR Part 75, Subpart E: Cost Principles Also includes non- competitive proposals including sole source (45 CFR 75.329(f))
  • 10.  Element B: Records of Procurement Actions ◦ Review of (5) five contracts AND supporting documentation that use federal award funds https://bphc.hrsa.gov/compliance/site-visits/sampling-review#contracts
  • 11.  Element B: Records of Procurement Actions ◦ Based on documentation:  Rationale for procurement method  Selection of contract type (sole source, competition, etc.)  Contractor selection or rejection  Basis for contract price ◦ Comply with 45 CFR 75.328  Open and fair competition and if not:  Item is only available from a single source  Public Emergency  Non-competitive is authorized by HRSA  Competition is determined to be inadequate after getting a few sources
  • 12.  Element C: Retention of Final Contracts ◦ Is the health center able to provide the final executed contract?  Retain financial records, supporting documents, statistical records, and all other records pertinent to the Health Center Program for a period of three years from the date of the submission of the final expenditures report to HHS  Element D: Contractor Reporting ◦ How do you oversee contractor performance?  Examples: Performance goals, invoices/payments reconciled, UDS submission
  • 13.  Element F: Required Contract Provisions ◦ Contracts that support HRSA approved scope of project  Includes Form 5A, Column II contracts
  • 14.
  • 15. Element E: HRSA Approval for Contracting Substantive Programmatic Work •HRSA approved (it will be in Notice of Funding Award [NOFA]) •A single entity for the majority of health care providers •Ex. Pass through entity, all employees are leased except for the CEO Elements G-J: Subrecipient Monitoring •Subrecipient supports the Health Center’s scope of project •Must comply with ALL HRSA Program Requirements •Health Center must monitor the subrecipient and keep records
  • 16.  Contracts (based on the HRSA requirements) ✓List of the entities involved  Who is the contract with? ✓List of services to be provided  Description of services ✓How will the health center pay for the services  Invoiced monthly, quarterly, etc. ✓How will the service be documented in the patient record?  Will the contractor send a treatment plan? Will it be documented in the health center’s health record?
  • 17. ✓Assurances of Credentialing and Privileging  “Provider agrees to provide Health Center with assurances that, during the term of this contract agreement, it, and as applicable, its individual healthcare practitioners furnishing the services to health center patients are and will remain: 1) duly licensed, certified and/or otherwise qualified to provide services hereunder, with appropriate training, education and experience in their particular field; 2) appropriately credentialed and privileged; and 3) eligible to participate in federal health care programs including Medicaid and Medicare” ✓Sliding Fee Discount Program (SFDP)  “Discounts are provided in a manner that meets all Health Center Program requirements, ex. health center applies its own sliding fee discount to amounts owed by eligible patients; contract contains specific sliding fee provisions; contracted services are provided by another health center which applies a sliding fee discount that meets structural requirements”
  • 18. ✓Monitoring contract performance  Ensuring that the contract is being carried out  What documents will be requested?  What happens if there is an issue with the service provided? ✓Data reporting expectations and intervals  Will data will be provided to know the contract is going well? Are you going to use invoices and cross reference payment as a reporting expectation? What about treatment plans received back in a certain period? ✓Provisions for record retention and access, audit and property management  Who owns the record? How long do you keep medical records? What about audits and access to records?
  • 19.  How to keep this requirement compliant ◦ Create a checklist of HRSA requirements for contracts  Paper or electronic tracking of all contracts  Ensure contracts are not expired, or monitor expiry date by using a system or a platform ◦ Use the HRSA Center Self-Assessment Worksheet for Form 5A: Services Provided ◦ https://bphc.hrsa.gov/sites/default/files/bphc/programrequirements/scope/fo rm-5a-self-assessment-review.pdf ◦
  • 20.  How to keep this requirement compliant ◦ Work with legal counsel for standard contract templates to ensure other contractual language ◦ Create addendums, if needed, for contracts (Quest, LabCorp, etc.)  If addendums are added, provide the entire contract and addendums for review during site visits ◦ Keep contracts in one place
  • 21. Contracts help health centers provide services we may not be able to offer in house Ensure they protect the health center and provide clarity to roles and responsibilities Can help to avoid expensive and potential risk and disputes
  • 24.  Element A: Standards of Conduct ◦ Do WRITTEN standards of conduct apply for the selection, award and administration of contracts that at a minimum apply to its procurement paid for in whole or in part by the federal award?
  • 25.  Element A: Standards of Conduct
  • 26.
  • 27.  Element B: Standards for Organizational Conflicts of Interests ◦ Do the standards prevent or mitigate any identified or perceived conflicts of interest? ◦ Does a health center’s audit (A133) identify any perceived or identified conflict of interest?  (Review the two (2) most recent audits and management letters)
  • 28.  Element C: Dissemination of Standards of Conduct ◦ How does your health center inform employees, officers, board members and agents of the conflict- of-interest standards?
  • 29.  Element D: Adherence to Standards of Conduct ◦ Reviewing of contracts from Chapter 12 (Contracts) on procurement process ◦ Reading Board of Directors meeting minutes ◦ Is there documentation of a perceived or apparent conflict in the past three (3) years?  If so, what were the steps and what do the disclosures state?
  • 30.  Considerations: ◦ Polices/Standard of Conduct must be reflective of current operational practices ◦ If your bylaws only address Conflict of Interest for board and officers, ensure that documentation is also provided for employees and agents of the health center ◦ A conflict of interest does not mean that a health center is out of compliance  Follow the policies and procedures that your health center has  Declare and document the conflict
  • 31.  Be mindful of conflicts in the organization ◦ Sometimes it’s difficult in smaller rural areas ◦ Certain companies may have an expertise/equipment that a health center needs ◦ Have employees sign conflict of interest statements  Keep in Human Resource (HR) files  A133 annual audits require Conflict of Interest Statements signed by the Board and Senior Team
  • 32.  https://bphc.hrsa.gov/programrequirements/compliancemanual/index. html  Health Center Self-Assessment Worksheet for Form 5A: Services Provided (hrsa.gov)  https://www.healthcenterinfo.org/  https://bphc.hrsa.gov/programrequirements/svprotocol  MOU-vs-Contracts_FINAL_20120117.pdf (changelabsolutions.org)
  • 33.  Jennifer Genua-McDaniel, BA (Hons), CHCEF ◦ Genua Consulting, LLC ◦ jgenua@genuaconsulting.com