Primary Practices in Underserved Areas: FQHCs and RHCs

Elizabeth Morgan Burrows, JDChief Executive Officer

Vermillion Parke Community Health CenterOctober 27th, 2010

What are all these “HCs?”

• FQHC – Federally Qualified Health Center– In hearing about the Affordable Care Act,

Community Health Centers are all FQHC• RHC – Rural Health Clinic• State-funded CHC – Community Health Center– Indiana provides tobacco settlement money to

fund state-funded CHCs. • FQHCs and RHCs can also be state-funded

CHCs but not all of them are.

Currently in Indiana…

• There are 47 state-funded Community Health Centers

• 19 of the 47 are Federally Qualified Health Centers

• 9 of the 47 are Rural Health Clinics

• 62 Rural Health Clinics (9 are state-funded CHCs)

MUA/MUP and HPSA

• To start an FQHC, the site must be located in a Medically Underserved Area or Population

• To start an RHC, the site must be in a MUA/MUP or Health Professions Shortage Area

Starting an FQHC

• FQHCs received funding under Section 330 of the Public Health Service Act. This funding is for operational expenses.

• Program Assistance Letter 98-23 spells out all the federal requirements.

• Must be located in an MUA or MUP.• New Access Point Funding is currently

available through HRSA.

FQHCs

• Non-profit entity• Governed by a consumer driven governing

board (51% of the board members must be patients of the clinic)

• Serve ALL patients regardless of their ability to pay through a Sliding Fee Scale

• Must provide primary, behavioral, and dental services either on-site or through an arrangement for ALL patients

Benefits of an FQHC

• Enhanced Medicaid and Medicare Reimbursement

• Medical Malpractice under the Federal Tort Claims Act

• 340B Drug Pricing• National Health Service Corps• Vaccines for Children

FQHC Look-Alike

• Organization meets all requirements of a Section 330 grant.

• No Grant funding for FHQC Look-Alikes.

• Receives all other FQHC “benefits.”

State-Funded CHCs

• Must meet a set of minimum standards outlined by the state

• These standards are less stringent than FQHC standards

• Must have a consumer-driven governing board

RHCs

• Special Medicaid and Medicare reimbursement

• Must be “certified” through CMS• Staffed at least 50% of the time with a

midlevel provider• Can be for-profit or non-profit• Can be provider-based• Must be in a rural area and in a HPSA OR

MUA/MUP

The Differences

FQHCs• Receive federal operational

grant funding• Subject to many more federal

regulations • Medicaid PPS Rate• Must be non-profit• Governed and owned by a

community governing board; cannot be owned by a hospital or health system (exception for public Entities

RHCs• Reimbursed at the

Medicare All-inclusive rate by Medicaid and Medicare

• Can be for-profit or non-profit

• Can be owned by a hospital or other health system

Lessons Learned since I started an FQHC 3 years ago.

If I knew then what I know now…

If I knew then what I know now – Community Support

• You need to have community support and the support from your medical community.

• You need individuals that are dedicated to making the health center a success.

• You also need patients!

If I knew then… - Governing Board

• The consumer-driven governing board is the integral foundation of the FQHC. Having board members that are committed to the health center’s mission is the key to success!

If I knew then… - Services

• You don’t have to do everything on your own from the beginning!

• Primary• Dental• Behavioral• Pharmacy• Outreach/Enabling Services

If I knew then… – Community Support

• Without the support of Union Hospital Clinton and the entire Union Hospital Organization, we would not be the success that we are now.

If I knew then… – Rapid Growth

• FQHCs are growing extremely quickly

• In 2008, we completed over 3,500 encounters.

• In 2009, over 8,000 encounters.

• In 2010, we are expected to complete over 14,000 encounters.

If I knew then… - Policies and Procedures

• FQHCs must have many policies and procedures established when they are started– QI plan– Credentialing Plan– After-hours Call Policy– Sliding Fee Scale implemented– Risk Management Plan– Recruitment and Retention Plan– And Many More

If I knew then… - The Deeming Process

• FQHCs received medical malpractice coverage under the Federal Tort Claims Act.

• Must be deemed for FTCA coverage.

• Deeming process reviews your QI plan and the staff and board’s efforts for continual improvement.

If I knew then… • FQHCs are hard work!• The feds are actually there to help!• There are always more people to

serve than the capacity that you have.

• Other FQHCs and associations are there to help.

• Serving members of my community is the most rewarding experience of my life.

Resources

• www.hrsa.gov• www.isdh.in.gov• www.raconline.org• www.indianapca.org• www.indianaruralhealth.org

Elizabeth Morgan Burrows, JDVermillion-Parke Community

Health Centeremorgan@vpchc.org

765-828-1003 or 765-492-9042