Health Center Referral Tracking Policies and Processes

There is a slight difference between the Site Visit Protocol and the HRSA Compliance Manual in regard to requirements surrounding referral tracking policies.

The HRSA Compliance Manual states, “Formal Written Referral Arrangement: If access to a required or additional service is provided and billed for by a third party with which the health center has a formal referral arrangement, this service is accurately recorded in Column III on Form 5A: Services Provided, reflecting that the health center is responsible for the act of referral for health center patients and any follow-up care for these patients provided by the health center subsequent to the referral. In addition, the health center ensures that such formal referral arrangements for services, at a minimum, address:

  • The manner by which referrals will be made and managed; and
  • The process for tracking and referring patients back to the health center for appropriate follow-up care (for example, exchange of patient record information, receipt of lab results).” (Compliance Manual, Chapter 4: Required and Additional Services, Demonstrating Compliance b.)

The Site Visit Protocol asks, “Does the health center have a process for making, tracking, and managing referrals for these services with the referral provider(s) (e.g., process for tracking whether patient presented at the referral provider or the outcomes of the referral visit)?” (Chapter 4: Required and Additional Services, Element a., Question 3).

The HRSA Compliance Manual states that the manner by which referrals will be made and managed should be addressed in the formal referral arrangements, yet the Site Visit Protocol simply asks if the health center simply has a process for making, managing, and tracking referrals.

Health centers almost always have referral processes (meeting the SVP standard) but rarely have the referral arrangements within the contracts (to meet the Compliance Manual standard). Though the SVP and Compliance Manual should be aligned in regard to the expectations of referral arrangements, our most conservative recommendation is to ensure your health center does both:

  • Maintain a process for making, tracking, and managing referrals, AND;
  • Ensure these processes are reflected in the formal written arrangements (for Column III Services).

As your health center works toward a state of continuous compliance, it is important to acknowledge the few areas that are not aligned in the HRSA Compliance Manual and the HRSA Site Visit Protocol. When reviewing your relationships documented on your HRSA Form 5A, review the HRSA Program Requirements and consider having some outside “eyes” on your documentation. This can be done by performing a mock site visit or inviting colleagues from other health centers to share best practices with you. As the Health Resources and Services Administration (HRSA) and the Bureau of Primary Health Care (BPHC) continue to work to align their key guidance documents, following the most conservative recommendations will help you more toward continuous compliance.