Category: Health Center Regulatory Issues

Health Center Regulatory Issues

GAO Identifies Lack of Internal Controls for HRSA Oversight of Grantees

In September 2014, the Government Accountability Office (GAO), an oversight arm of Congress, published a report (Action Taken to Train and Oversee Grantee Monitoring Staff, But Certain Guidance Could Be Improved) in which it found that despite efforts by HRSA to increase and improve its guidance and training related to monitoring grantees, key components of …

Health Center Regulatory Issues

BPHC Announces Reorganization – Implementation Set for Beginning of New Year

On October 23, 2014, BPHC issued a Federal Register Notice in which it announced a reorganization of its Offices and Divisions.  The Notice indicates that the reorganization is effective immediately.  However, during a BPHC All Programs Webcast that took place that same afternoon, Jim Macrae indicated that the reorganization would be implemented early next year.  …

Health Center Regulatory Issues

OIG Issues Proposed Rule that Revises Safe Harbors under the Anti-Kickback Statute and Amends Regulatory Exceptions Related to Beneficiary Inducements

The OIG has issued a notice of proposed rulemaking (NPRM) that would revise the Medicare and Medicaid safe harbors under the anti-kickback statute and amend the civil monetary penalty rules pertaining to beneficiary inducement and gainsharing.  Among the revisions to the existing safe harbors to the Anti-Kickback Statute, the OIG intends to codify protection for …

Health Center Regulatory Issues

HRSA Announces Inclusion of 340B Compliance Questions in Operational Site Visit

In its Primary Health Care Digest dated October 22, 2014, BPHC announced that Operational Site Visits (OSV) conducted on or after October 1, 2014 for health centers that participate in the 340B Discount Drug Pricing Program will include a “brief assessment of compliance with 340B requirements.”  According to HRSA, the OSV review team will assess …

Health Center Regulatory Issues

HRSA Issues Much Anticipated Sliding Fee Discount Program Policy

On September 22, 2014, HRSA issued the much anticipated final policy on “Sliding Fee Discount and Related Billing and Collection Program Requirements” (Policy Information Notice #2014-02). The new policy, which applies to grantees and FQHC Look-Alike entities, clarifies various aspects of the Sliding Fee Discount Program (SFDP), as described below in detail, and was effective …

Health Center Regulatory Issues

HRSA’s September 3, 2014 Weekly Digest Includes Clarifications Regarding HRSA's Role in Monitoring

On September 3, 2014, the weekly HRSA Primary Health Care Digest included two clarifications regarding HRSA’s role in financial and programmatic monitoring. With respect to the former, HRSA will no longer require submission of Financial Recovery Plans as the formal monitoring of financial performance. HRSA stressed that while it will continue to assess health center …

Health Center Regulatory Issues

HRSA issues PAL on Updated Change in Scope Process

On August 28, 2014, HRSA issued Program Assistance Letter #2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines. The PAL expands on clarifications in PAL 2013-03, issued last year, and applies to both grantees and FQHC look-alike entities. Specifically, the PAL clarifies the following timelines: Submission of Complete Change in Scope (CIS) …

Health Center Regulatory Issues

Are You Ready? NACHC Offering Trainings on Medicare FQHC PPS

As you all know, CMS published a final rule on the Medicare Prospective Payment System for Federally Qualified Health Centers (FQHCs) as mandated by the Affordable Care Act. The final rule is estimated to increase the ability and capacity of FQHCs to provide essential and affordable services by increasing Medicare payments. The new payment system will …

Health Center Regulatory Issues

HRSA Issues Revised and Updated FTCA Manual

On July 21, 2014, HRSA issued a new Federal Tort Claims Act: Health Center Policy Manual – which updates and supersedes the prior manual (PIN 2011-01), as well as a Program Assistance Letter (PAL) explaining the updates and modifications (PAL 2014-09). The new updated manual reflects an expansion in Federal Tort Claims Act (FTCA) coverage …

Health Center Regulatory Issues

Court of Appeals Rulings Don’t “Blow Up” the ACA

By Dashawn Groves On June 22, 2014, two U.S. courts of appeals issued conflicting rulings on whether the health insurance subsidies are available to ONLY people in states that have created their own exchanges or to all residents regardless if the exchange was created by the state or federal government. The cases center on a …