HRSA has started conducting random FTCA site visits of both initial applicants and deemed grantees to determine compliance with FTCA program requirements. As described in PAL 2014-03, factors that may prompt a site visit include, but are not limited to, the submission of an initial deeming application; submission of documentation which indicates non-compliance; follow-up on prior site visit findings/issues; history of repeated conditions on the health center’s grant; and/or a history of medical malpractice claims. Non-compliance with FTCA program requirements is grounds for a negative deeming determination.
“Given that HRSA can conduct an FTCA audit for reasons enumerated in PAL 2014-03 or for other unstated reasons, every health center must be prepared for such a visit,” said Mary Bree, an attorney with Feldesman Tucker Leifer Fidell. “Health centers should have the appropriate policies in place and all of their documentation up-to-date. They should also know the parameters of an FTCA site visit to ensure that it does not go beyond scope.”
Health centers are typically given several weeks of notice before the audit. The visits are conducted by a FTCA staff member along with MSCG contractor(s). The site visits last 2.5 days during which time risk management, QI/QA, and credentialing policies and procedures and supporting documentation are reviewed. The site visit team also meets with health center leadership and the Board. The site visit team provides findings and recommendations during an exit conference.
If the audit team finds a lack of implementation of the FTCA program requirements, HRSA may deny deeming the health center.
To prepare for an FTCA audit, consider attending the upcoming live training, An In-Depth Look at FTCA Coverage, taught by attorneys from Feldesman Tucker Leifer Fidell LLP. This 1.5 day training is devoted to compliance with FTCA coverage requirements and potential risk areas for health centers. Please check out HealthCenterCompliance.com for additional information pertaining to FTCA coverage and HRSA inspections.