FTCA Application Changes for CY 2023

On February 18, 2022, HRSA released their “PAL 2022-01 Calendar Year 2023 Requirements for Federal Tort Claims Act (FTCA) Coverage for Health Centers and Their Covered Individuals”.

There are three important changes all FTCA-applicants should know about:

• Some questions were removed from the Quality Improvement/Quality Assurance Section, as these questions are similar to information that is also collected in the Risk Management Section. This change is intended to reduce duplicative efforts.

• Applicants will be required to submit a Credentialing List with provider information to help verify compliance with deeming requirements.

• All provider information on the Credentialing List must have been renewed (“re-credentialed/re-privileged”) within the last two years from the date of your FTCA application submission.

The first set of changes in which some QI/QA questions were removed does not significantly change the FTCA application process for health centers. If anything, it should streamline the process and reduce the duplication of responses.

Health centers must submit a “Credentialing List” that contains all the required fields.

As for the Credentialing List, most health centers likely are already able to run a report or list of these sorts. This list must include:

• First Name

• Last Name

• Title

• Clinical Staff Type (i.e., Licensed Independent Practitioner (LIP), Other Licensed or Certified Practitioners (OLCP), and Other Clinical Staff (OCS)

• Most recent credentialing date (which must be in the last 2 years of FTCA application date)

• Most recent privileging date (which must be in the last 2 years of FTCA application date)

During the application process you will not be required to submit verification or supporting materials, but your health center should obviously have this documentation current and accurate to support the data on your Credentialing List.

All renewals must have been completed within the last 2 years from the date of your application submission date.

For the purposes of this application, according to the PAL, “documentation of a credentialing date within the last 2 years from application submission indicates that the health center has properly credentialed the individual in accordance with the Health Center Program Compliance Manual”.

This is an important point to note! In the “HRSA Site Visit Protocol: Credentialing and Privileging File Review Resource”, the document specifically states that, “The health center chooses the timeframe for recurring credentialing and renewal of privileges (for example, every 2 years)”. The most common frequency we see is 2 years. However, in our work with health centers over the years, we have seen as frequent as 1-year renewal cycles up to 3-year renewal cycles. If you are one of those health centers who has a renewal cycle longer than 2 years, you must ensure that for your FTCA application, all renewals have been completed within the last 2 years from the date of your application submission date.

The RegLantern platform has got you covered for this new update. If you are using RegLantern’s Credentialing & Privileging module, you are able to export this Credentialing List as required by the FTCA PAL. If you have any questions or need help preparing for your HRSA/FTCA application submission, please contact us on our website here.

EDIT (6/10/22): The FTCA application in EHB will not accept document uploads of the Credentialing & Privileging Staff List. Health Centers will be required to manually type in the information into the EHB application. This is not a quick process so leave plenty of time to do this!