Continuous HRSA Compliance: Contract Program Monitoring

Health centers are commonly confused about what it means to “monitor contract performance” for the contracts the health center enters into to provide health center services or to acquire other goods and services in support of the HRSA-approved scope of project. This is a requirement in HRSA’s Program Requirements and can be found in the HRSA Site Visit Protocol, Chapter 12, Element f.

First, it’s important to look at and think through what HRSA’s intent is in requiring health centers to have this language in a contract. Well, if you boil all of HRSA’s Program Requirements down, you start to see a few themes emerging. One could argue that HRSA wants its grantees to provide continuous documentation that the health center provides as many patients as possible, access to the highest quality care, that is responsive to the needs of the community, while being good stewards of the government’s resources. That pretty much covers it, doesn’t it?

So, health center leaders can extrapolate that the requirement to “monitor” contract performance is mandatory because HRSA wants to ensure that this service being provided on behalf of the federal government is providing a service that is accessible, high-quality, responsive to the needs of the community, and are good stewards of the government’s resources. Though HRSA is not prescriptive in how health centers are to monitor contract performance, leaders can get some good ideas by thinking through these themes.

Some suggestions for how a health center could evaluate whether a service is accessible and responsive to the needs of the community might be to utilize Patient Satisfaction Surveys specific to the service. Determining whether a service is high-quality might be measured by evaluating related metrics, quality outcomes, or key performance indicators (KPIs). Assessing financial stewardship may be performed by reviewing periodic audits or financial reports.

When determining how your health center will evaluate a specific service, individualize the language to be specific to that vendor and service. For example, a contract with a phone call center may require a totally different set of interventions than a locum tenens/staffing contractor. There is likely no, “one-size-fits-all” that will work for every service contract.

Here is an example of some language that could apply to some of your contracts:

Contractor Performance Monitoring

[HEALTH CENTER] will utilize the following mechanisms to monitor contractor performance:

• Patient Satisfaction: At least annually, [HEALTH CENTER] will survey a sample of patients who have received services provided by [PARTNER] and ask questions pertaining to services received from [PARTNER]. Survey results will be reviewed by [HEALTH CENTER] and shared with [PARTNER] as appropriate. Any areas of improvement will be addressed and [HEALTH CENTER] will develop a plan for improving patient satisfaction.

• Follow-Through With Responsibilities Outlined in MOU: At least annually, [HEALTH CENTER] will review this MOU and evaluate the activities, services or goods agreed to be provided.

• Quality Outcomes: Each year, [HEALTH CENTER] will establish health center outcome goals for clinical metric [METRIC NAME]. [HEALTH CENTER] will share metric outcomes in relation to the stated goals with [PARTNER] at least annually. If outcomes fall below the stated goal, [HEALTH CENTER] will develop an intervention to work to improve the clinical outcome.

• Audits of Financial Reports/Invoices: Each quarter, the health center will audit invoices/financial reports for services provided to health center patients to ensure billing is according to the agreement set in this MOU.
  

When health centers work to not only be knowledgeable of HRSA’s requirements but also understand the intent behind them, leaders will be more successful in drafting a HRSA-compliant contract. If you or your health center would like help moving toward continuous HRSA compliance, please contact the RegLantern team of experts at 1-833-REGLANTERN or visit us at RegLantern.com. (This article should not serve as legal advice. Before working on any contracts or MOUs, please consult your own legal advisors.)