In this section:
Primary Reviewer: Clinical Expert
Secondary Reviewer: TBD
Authority: Section 330(b)(1)(A)(IV) and Section 330(k)(3)(A) of the Public Health Service (PHS) Act; and 42 CFR 51c.102(h)(4), 42 CFR 56.102(l)(4), 42 CFR 51c.303(a), and 42 CFR 56.303(a)
Health Center Program Compliance Manual Related Considerations
Documents the Health Center Provides
- Operating procedures for addressing medical emergencies during health center’s hours of operation.
- Operating procedures for responding to patient medical emergencies after hours.
- Staffing schedules for up to five service delivery sites that identify at least one individual with current certification in basic life support at each site. Include a copy of those individuals’ current certifications (for example, credentialing file for licensed independent practitioner or other licensed or certified practitioner, certification of training if non-clinical staff).
- If the health center uses its providers for after-hours coverage: Health center provider on-call schedules.
- If the health center uses non-health center providers for after-hours coverage: After-hours written arrangements with non-health center providers/entities (for example, formal agreements with other community providers, nurse call lines).
- Information provided to patients for accessing after-hours coverage.
- Three samples of after-hours clinical advice documentation in patient records.1 Include associated documentation of follow-up.
Notes:- Select a sample based on after-hours calls that necessitated follow-up by the health center. If the health center has fewer than three after-hours calls that required follow-up, make up the difference with after-hours call documentation that did not require follow-up.
- Use live navigation of the Electronic Health Record (EHR), screenshots from the EHR, or other patient record formats.
- Procedures for tracking, recording, and storing of after-hours coverage interactions and any follow-up (for example, log of patient calls).
Note: Alternatively, a health center can use live navigation of its system.
Compliance Assessment
Select each element below for the corresponding text of the element, site visit team methodology, and site visit finding questions.
The health center has at least one staff member trained and certified in basic life support present at each HRSA-approved service site (as documented on Form 5B: Service Sites) to ensure the health center has the clinical capacity to respond to patient medical emergencies2 during the health center’s regularly-scheduled hours of operation.3
Site Visit Team Methodology
- Interview health center clinical leadership about:
- Staff members trained and certified in basic life support present at each HRSA-approved service site; and
- The health center’s clinical capacity to respond to patient medical emergencies during the health center’s regularly-scheduled hours of operation.
- Review the operating procedures for provisions that ensure that all service delivery sites on Form 5B have at least one individual per site present during the health center’s regularly-scheduled hours of operation to respond to patient medical emergencies.
- Review the sample of staffing schedules and of basic life support certifications to confirm that the individuals listed have current certification in basic life support and are present at each site during the health center’s regularly-scheduled hours of operation.
Site Visit Findings
- Is there documentation that the health center ensures at least one staff member (clinical or non-clinical) trained and certified in basic life support is present at each HRSA-approved service delivery site during the health center’s regularly-scheduled hours of operation?
Response is either: Yes or No
If No, an explanation is required, including stating what provisions the health center has in place to respond to patient medical emergencies during regularly-scheduled hours of operation at its sites.
The health center has and follows its applicable operating procedures when responding to patient medical emergencies during regularly-scheduled hours of operation.
Site Visit Team Methodology
- Review the health center’s operating procedures for responding to medical emergencies.
- Interview CMO, Clinical Director, or equivalent leadership about how the health center HAS or WOULD follow its operating procedures when responding to a patient emergency.
Site Visit Findings
- Does the health center have operating procedures for responding to patient medical emergencies during the health center’s regularly-scheduled hours of operation?
Response is either: Yes or No
If No, an explanation is required.
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Did the health center describe how it either has responded to or is prepared to respond to patient medical emergencies during regularly-scheduled hours of operation (for example, staff training or drills on use of procedures)?
Response is either: Yes or No
If No, an explanation is required.
The health center has after-hours coverage operating procedures, which may include formal arrangements4 with non-health center providers/entities, that ensure:
- Coverage is provided via telephone or face-to-face by an individual with the qualification and training necessary to exercise professional judgment in assessing a health center patient's need for emergency medical care;
- Coverage includes the ability to refer patients either to a licensed independent practitioner for further consultation or to locations such as emergency rooms or urgent care facilities for further assessment or immediate care as needed; and
- Patients, including those with limited English proficiency (LEP),5 are informed of and are able to access after-hours coverage, based on receiving after-hours coverage information and instructions in the language(s), literacy levels, and formats appropriate to the health center’s patient population needs.
Site Visit Team Methodology
- Review the health center’s operating procedures.
- Review any provider on-call schedules for after-hours coverage.
- Review any after-hours written arrangements with non-health center providers/entities (for example, formal agreements with other community providers, nurse call lines).
- Review the instructions or information provided to patients for accessing after-hours coverage.
- Using contact information for after-hours coverage (for example, phone number provided by front desk staff, on signage, in brochures, on health center’s website), call the health center once the health center is closed.
- Interview CMO, Clinical Director, or equivalent health center leadership as well as outreach or front desk staff about methods of informing patients of after-hours coverage and how the health center addresses barriers, including those due to LEP or literacy levels, that patients may face in accessing after-hours coverage.
Site Visit Findings
- Does the health center have written operating procedures or other documented arrangements for responding to patient medical emergencies after hours?
Response is either: Yes or No
If No, an explanation is required.
- Based on the interview with clinical leadership and front desk staff, is information provided to patients at all health center service sites (on Form 5B) on how to access after-hours coverage?
Response is either: Yes or No
If No, an explanation is required.
- Has the health center addressed barriers that patients face when attempting to use the health center’s after-hours coverage? This includes barriers due to LEP or literacy levels.
Response is either: Yes or No
If No, an explanation is required.
- Based on the after-hours call you made to the health center, did you confirm the following:
- 7.1 You were connected to an individual with the qualification and training necessary to exercise professional judgment to address an after-hours call?
Response is either: Yes or No
- 7.2 This individual can refer patients to a covering licensed independent practitioner for further assessment or to locations, such as emergency rooms or urgent care facilities, for immediate care?
Response is either: Yes or No
- 7.3 Provisions are in place for calls from patients with LEP?
Response is either: Yes or No
If No was selected for any of the above, an explanation is required.
- 7.1 You were connected to an individual with the qualification and training necessary to exercise professional judgment to address an after-hours call?
The health center has documentation of after-hours calls and any necessary follow-up resulting from such calls for the purposes of continuity of care.6
Site Visit Team Methodology
- Interview CMO, Clinical Director, or equivalent health center leadership about after-hours call documentation.
- Review the health center’s operating procedures or documentation of any arrangements (for example, contract with nurse call line) for responding to patient medical emergencies after hours.
- Review three samples of after-hours documentation within patient records provided by the health center, including associated documentation of follow-up. The samples will be based on after-hours calls that necessitated follow-up by the health center.
Notes:- If the health center has fewer than three after-hours calls that required follow-up, the health center will make up the difference with after-hours call documentation that did not require follow-up.
- Use live navigation of the Electronic Health Record (EHR), screenshots from the EHR, or other patient record formats.
- Review the health center’s tracking, recording, and storing of after-hours coverage interactions and any follow-up either through review of health center procedures or through live navigation of the health center system.
Site Visit Findings
- Does the health center document after-hours calls or, if no after-hours calls have been received, does the health center have the capacity to document these calls?
Response is either: Yes or No
If No, an explanation is required.
- Based on review of systems or the sample of records, does the health center provide the necessary follow-up? For example, the health center contacts the patient within a certain number of days to check in on the patient’s condition or to schedule an appointment.
Note: For a health center with no after-hours calls that required follow-up (for example, a newly-funded health center that recently started its operations), review operating procedures and interview health center staff to respond to this question.
Response is either: Yes or No
If No, an explanation is required.
Footnotes
1. Health centers may choose to provide samples of patient records before or during the site visit. If patient records will be provided during the site visit, this should be communicated to the site visit team before the site visit to avoid any disruption or delay in the site visit process.
2. Medical emergencies may, for example, include those related to physical, oral, behavioral, or other emergent health needs.
3. See [Health Center Program Compliance Manual] Chapter 6: Accessible Location and Hours of Operation for more information on hours of operation.
4. See [Health Center Program Compliance Manual] Chapter 12: Contracts and Subawards for more information on oversight over such arrangements.
5. Under Section 602 of Title VI of the Civil Rights Act and the Department of Health and Human Services implementing regulations (45 CFR Section 80.3(b)(2)), recipients of federal financial assistance, including health centers, must take reasonable steps to ensure meaningful access to their programs, services, and activities by eligible limited English proficient (LEP) persons. Visit Office for Civil Rights: Guidance to Federal Financial Assistance Recipients Regarding Title VI and the Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons - Summary for further guidance on translating vital documents for LEP persons.
6. See [Health Center Program Compliance Manual] Chapter 8: Continuity of Care and Hospital Admitting for more information on continuity of care.