Common HRSA Compliance Questions: Referral Tracking For Column III Relationships

Though the development of the new HRSA Compliance Manual and Site Visit Protocol has removed a great deal of subjectivity from the Operational Site Visit process, there still exist some areas that are consistently confusing for health centers. Over the next few blog posts, our team will highlight some of these areas and give our opinions about how best to navigate these common issues. This week, we will highlight a common question involving referral tracking policies and referral arrangements. When reviewing the various health center compliance documents, the astute observer will note that there is a slight difference between the Site Visit Protocol and the HRSA Compliance Manual in regards 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 has a process for making, managing, and tracking referrals. Health centers almost always have referral processes (meeting the SVP standard) but rarely have the process for tracking referrals within the contracts (to meet the Compliance Manual standard).

Though the two documents are not aligned, we recommend the more conservative approach of having both a policy for tracking referrals and referencing the process within the written referral arrangement. Stay-tuned for more common compliance pitfalls!