FTCA Deeming – Don’t forget the Compliance Manual!

I’ve been thinking about our annual FTCA deeming application lately – actually my clients have been helping me with that as some are sending emails anxiously anticipating the submission. Just an FYI, HRSA EHB sent out a notice on March 29th stating that it will reopen and resume accepting applications on May 4th, 2018. But really, there’s no need to wait until then if you are ready to get going – which I would recommend. We just don’t know when those grants they’ve been talking about will be posted and, if we’ve got our act together on FTCA we can focus on expanding our programs and services when they are released, instead of trying to figure out how to document your quarterly risk management assessments.

Speaking of risk management assessments – did anyone get stumped on that last year? The Compliance Manual has a chapter on FTCA, Chapter 21, and included in the Related Considerations items the following: “The health center determines how to conduct and document the completion of quarterly risk management assessments.” P. 85. Yea, so this is HRSA tell you that they aren’t going to tell you what to include. Here’s a thought…

My clients and I had quite a lively discussion about this list last year and after some debate we decided to start asking ourselves what we do to assess the clinics’ performance in any area. Literally, we started from January and worked our way through the past year and the upcoming year listing everything we do to review, assess, track, and survey our patients, our staff, our EHRs, and our work. In the end, we were amazed at how many things we were doing that met our thoughts on what the quarterly risk assessments should include. Keep in mind that not all the assessments have to be completed quarterly, you are just required to complete quarterly assessments. We combined semi-annual, annual, bi-annual, quarterly, and monthly assessments to make up our final list. Here’s a partial list of the areas we looked at and found assessments being conducted or opportunities for assessment that we added to our risk management quarterly assessment quarterly calendar.

  • Patient Complaints and Grievances
  • Hazard Vulnerability Assessment
  • Meaningful Use
  • Compliance Review
  • Review of Forms 5A, 5B, 5C
  • Employee Survey
  • 340B Program Compliance
  • Billing – Aging reports

Let me know if you would like the complete list. And remember, FTCA is covered extensively in Chapter 21 of the Compliance Manual – it’s worth a read!

– Eileen



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