The Health Center Program mandates that in-scope services, as listed in a health center’s Form 5A, are provided directly by the health center, by contract, and/or by referral. If a health center achieves such access via contract and/or referral, then the health center must maintain a written agreement with the other provider (i.e., a Purchase of Services Agreement and/or a Referral Agreement). There are a myriad of provisions that must be addressed in such written agreements in order to achieve HRSA compliance. For example, Purchase of Services Agreements must address record retention and programmatic reporting obligations, and Referral Agreements must describe how referrals will be made and managed. In addition, both Referral Agreements and Purchase of Services Agreements must include certain representations regarding fee discounts and provider credentialing/privileging.

In practice, inadequate Purchase of Services Agreements and Referral Agreements is one of the most common reasons for non-compliance findings stemming from Operational Site Visits. Drafting Purchase of Services Agreements and Referral Agreements that include the necessary provisions can be challenging, in part because the applicable requirements are described in multiple Chapters within the HRSA Health Center Program Compliance Manual.

Health centers are accordingly encouraged to become familiar with the applicable requirements and confirm that their respective Referral Agreements and Purchase of Services Agreements include the necessary provisions.

Join Marcie Zakheim and Carrie Riley for a deep dive into FTLF’s Purchase of Services Agreement: Checklist and Referral Agreement: Checklist.

This session will walk through these checklists to:

• Explain the three service delivery methods within the Form 5A;
• Explain the required provisions and highlight the applicable element from the HRSA Health Center Program Compliance Manual;
• Discuss drafting alternatives that satisfy the underlying HRSA requirement;
• Review optional yet recommended provisions; and
• Discuss common pitfalls and strategies to overcome them.

Whether you have been using FTLF’s checklists for years, are a Section 330 Health Center Program Toolkit subscriber, or are looking for support to strengthen your agreements and comply with requirements, this Document Deep Dive will provide valuable information and insight for your health center.