Supplement to Federal Tort Claims Act (FTCA) Health Center Program Site Visit Protocol: Guidelines and Logistics for Virtual HRSA/BPHC FTCA Site Visits

Introduction

U.S. Department of Health and Human Services (HHS) Secretary Alex Azar issued a declaration of a national public health emergency regarding COVID-19 on January 31, 2020. Due to the potential impact to health care organizations during the COVID-19 public health emergency, the Health Resources and Services Administration (HRSA)/Bureau of Primary Health Care (BPHC) postponed in-person site visits, including FTCA site visits until further notice.

Purpose

FTCA Site Visits are a critical part of the oversight and compliance process. This supplement to the FTCA Site Visit Protocol (SVP) provides an overview of modifications taken to adapt the on-site FTCA site visit processes to a virtual site visit format.

Logistical Guidelines for the Conduct of Virtual Site Visits

HRSA will schedule a virtual site visit to further assess compliance with the statutory deeming requirements of the FTCA Health Center Program, and compliance with Health Center Program requirements.

Pre-Site Visit Preparation

• A HRSA representative will contact the health center via email and by phone regarding their readiness for the virtual site visit and identify dates for the visit.
  • Health centers are encouraged to review the FTCA Health Center Policy Manual (PDF - 406 KB), the FTCA SVP and Health Center Compliance Manual.
• The health center will participate in a "Pre-Site Visit" conference call with the site visit team and HRSA representative at least 4 weeks prior to the scheduled FTCA site visit start date, with the exception in an emergent situation.
• In advance of this call, HRSA’s technical assistance contractor, Management Solutions Consulting Group (MSCG) will provide the applicant with information and conduct training on file sharing, Citrix File Share, and the GoToMeeting platform used to facilitate the virtual site visit process.

Documentation

• The health center will provide all documents noted in the SVP (both those indicated as "Prior to the Site Visit" and "Onsite") and those indicated below in the Supplemental Methodology and Documentation for Virtual Site Visits section at least 4 weeks prior to the scheduled start date of the FTCA virtual site visit using the file sharing platform, Citrix, provided by MSCG.
• The file sharing platform is structured to align with the SVP sections. The applicant should place documents in the appropriate folders, which is organized by each SVP section.
  • Health centers are asked to adhere to the specific naming convention to upload files. Files required to be uploaded will have descriptive file names that align with the documentation referenced in the SVP. For example, the file name for board minutes might be labeled as “Board Minutes” along with the date of the board meeting.
  • Important: Please note that the same document may need to be uploaded into more than one folder.

Virtual Site Visit Schedule and Logistics

• To allow for flexibility in scheduling interviews and interactions with health center staff and board members, the virtual site visit may be spread out over the course of a 3-5 day period (Monday-Friday).
• The site visit team and the health center will develop a mutually agreed upon agenda for the site visit.
  • The agenda will include designated times for: entrance/exit conferences, virtual site tours, meeting board members, and interviews and interactions necessary to support the compliance analysis. The agenda will also include debriefs with the Executive Officer (CEO).
  • In order to complete the site visit, staff and board members must be available during the week of the site visit for the scheduled interviews and interactions required by the SVP.
  • The site visit team will schedule any necessary phone interviews and video conferences with key staff and board members during business hours, as agreed upon by the site visit team.
  • To the extent possible, time zone differences, between the site visit team and the health center will be taken into consideration in the development of the structured agenda to facilitate timely conduct of meetings and interview conferencing times.
• HRSA representative(s) will be present at interviews, video conferences, and site tours.
• The health center should have staff available to facilitate the use of technology and help to ensure sessions utilizing these systems are able to start on time.
• Recording during the virtual site visit, including site tours, interviews, entrance conferences, and exit conferences, is not permitted.

Video Conferencing Expectations

• When possible, interviews and interactions will be conducted via video conferencing utilizing GoToMeeting. This will include interviews with the board of directors, unless precluded by software, hardware, and/or connectivity issues. In such cases, audio-only is sufficient.

Live Virtual Tour Expectations

• The health center will conduct a live virtual tour for the site visit team of the service site (or, if the health center has multiple service sites, at least two service sites) utilizing GoToMeeting software and the applicant’s equipment (i.e., phone, tablet, computer camera). MSCG will provide training and information to assist in conducting the virtual site visit tour.
  • This tour will include both the exterior and interior of the building, front desk, and clinic, other areas may include treatment room, medication storage area, lab (if onsite), and specialty areas (as requested), consistent with an “in-person” tour.
  • The site visit team may provide direction to the health center tour guide if the team wants to review something further.
  • The site visit team may also request to speak informally with staff as they tour.
• Consistent with the SVP, these virtual tours will be scheduled during the site visit week and, if there are multiple sites, the site tour locations will be communicated by HRSA.

Screen Sharing Expectations

• The site visit team may request screen sharing of documents and systems to facilitate joint review of certain documentation (i.e., system walkthrough, Electronic Health Record (EHR) demo, and lab/sterilization records).

General Information

• HRSA will request contact information for select health center staff and board members (email and phone numbers) for the purposes of scheduling interviews.
• Health center should provide floor plan of the service site(s) that will be toured.