Webinar Available Here! https://attendee.gotowebinar.com/register/3127765771891588950?source=slideshare
Join us for this informative presentation which will cover the following:
1) HRSA Minimum Requirements - We will discuss all minimum requirements as defined in the Site Visit Protocol
2) Contract components that should be included - Sample agreements will be reviewed along with a discussion regarding the necessary components to make a successful agreement: Dos and Don'ts of what to include and what should not be included
3) Best Practices - We will discuss how to develop a process/procedure that not only meets, but far exceeds, the minimum HRSA Requirements and makes administering contracts a manageable process while maintaining proper oversight over the agreements
3. Agenda
• HRSA Minimum Requirements
• Policy
• Components that should/should not be included
• Contract Management Oversight
4. HRSA Minimum Requirements
• Determine whether an individual contract will result in the disbursements
of Federal Funds.
• HC contracting for substantive programmatic work must have approval.
• Procurement procedures that comply with federal procurement standards.
• Records of procurement actions paid for with federal dollars.
• Retain final contracts related to procurement for items paid for with
federal dollars.
• Contracts reviewed include ANY that support the scope of project, even if
the federal budget only covers payroll.
5. HRSA Minimum Requirements
• Provide full and open competition. There are some instances that this
is not required, in cases where you have a single source, the
competitive process will create delays or you have authorization from
HRSA.
• Contracts must include services to be performed, a schedule of rates
and payment methods.
• Oversee contractors to ensure their performance is adequate and
follows the agreement.
• Retain financial records supporting the contract.
• If you are a subrecipient, all of the rules apply and it must be monitored
and governed contractually.
6. Demonstrating
Compliance
1. Policies and procedures should be clear and
ensure that the HC follows appropriate
standards.
2. Retain final contracts and supporting
documentation, including bids where
appropriate.
3. Maintain and verify that records and reports
support the deliverables.
4. All contracts that support the HC Scope
should include specific activities to be
performed.
5. Records of items purchased with federal
funds indicates how the contractor was
selected, contract price.
7. Policy/Procedure
The policy of Health Center Name (HC) regarding its
procurement standards incorporates those required by
the Federal Government in the U.S. Department of
Health and Human Services (DHHS) regulations found at
45 CFR Part 74. As revisions are made to 45 CFR Part
74 they are automatically included in HC’s Policy.
No employee, officer or agent may participate in the
selection, award, or administration of a purchase or
contract supported by a Federal award if he or she has a
real or apparent conflict of interest.
All procurement transactions shall be conducted in a
manner to provide, to the maximum extent practical,
open and free competition. HC will be alert to
organizational conflicts of interest or non-competitive
practices among contractors that may restrict or
eliminate competition or otherwise restrain trade. In
order to ensure objective contractor performance and
eliminate unfair competitive advantage, contractors that
develop or draft bids and/or requests for proposals
should be excluded from competing for such
procurements.
Awards shall be made to the bidder/offer whose
bid/offer is responsive to the solicitation and is most
advantageous to the recipient, price and other factors
considered. Solicitations shall clearly set forth all
requirements that the bids/offers may be rejected when
it is in the recipient’s interest to do so.
8. Policy/Procedure
Purchase Thresholds
• Specific procurement requirements vary
according to the dollar amount of the
purchase or contract.
• Micro Purchases of supplies or services are
those that do not exceed $10,000.
• Micro purchases shall be distributed
among qualified suppliers.
• No competitive quotes are required if
management determines that the price is
reasonable.
• Small Purchase requirements apply when
purchases are between $10,000- $250,000
• Price or rate quotes must be obtained from at
least two, preferably three sources.
• Prices can be obtained from published or
online price lists.
9. Policy/Procedure
Purchase Thresholds
• Purchases over $250,000*
• Sealed bids are used for purchases over
the simplified Acquisition Threshold.
• This method is the most common
procurement method for construction
contracts.
• Formal solicitation is required
• At least three vendors’ quotations
required, if possible.
• Cost or price analysis required.
• The fixed price (lump sum or unit
price) is awarded to responsible
bidder who conformed to all material
terms and is the lowest price.
12. Components
Term of the Agreement
Licensure Requirements
Payment Expectations
Record Retention
Liability Insurance
Signature
Fee Schedule
Who is responsible for billing
Sliding Fee
14. Achieving
Excellence
1. Assign contract management to specific
staff member.
2. Maintains contract list and monitors review
by appropriate parties.
3. Maintains ShareFile with all contracts
including fee schedules and any supporting
documentation.
4. Utilize software made for this purpose
specifically.
5. Make sure to include all exhibits with the
contract.
15. Contract Spreadsheet
PRODUCT/SERVICE
Contract
Signature
Date
Utilize
Federal
Fund (Y/N) BILLING FREQUENCY TERM
RENEWAL
DATE AMOUNT NOTICE REQUIRED Renewal
Responsible
Person
Review
Date Initial
Contract Pharmacy Management 2/12/2019 No Monthly Evergreen $ 3,500.00 7 Days Evergreen Andrea 2/19/22
MEDICAIRE BILLING 10/25/2013 No MONTHLY MONTHLY N/A $ 325.00 NO Evergreen Melisa 2/2/22
CREDENTIALING 4/29/2014 No MONTHLY MONTHLY MAY $ 1,200.00 60DAYS Evergreen Melisa 2/2/22
Patient Laboratory 10/29/2018 No Monthly Evergreen N/A Per Lab test 30 Days written Evergreen Andrea 10/29/21
RUG CLEANING 6/30/2011 No MONTHLY 60 MO JULY $ 260.01 YES Jul-20 N/A-INVOICE
COPIER LEASE 12/21/2010 No MONTHLY 60 MO $ 294.50 $1.00 BUY OUT N/A-INVOICE
Hospital Admissions - ER 10/5/2018 No N/A Evergreen N/A N/A 30 Dayes written Evergreen Andrea 10/5/21
RENT 10 YEAR 7/1/2014 No MONTHLY MONTHLY JULY $ 12,361.00 6MONTHS July, 2024 N/A-INVOICE 2/1/21
EMPLOYEE SERVICES 6/26/2020 No MONTHLY MONTHLY JULY $100 @ HOUR 90 DYS WRITTEN Evergreen 7/1/21
16. Final tips & takeaways
• In an FQHC, resources are limited.
• It is important that we are all good stewards of
all funds.
• Ensure that all your agreements meet the
needs of the organization.
• Review the agreements at least annually to
maintain continued compliance.
• When developing policies and procedures
copy required statements out of the
compliance manual to ensure compliance.