FTCA Required Trainings

If your health center is FTCA-deemed or is applying to be deemed, you are required to ensure your staff and board are trained annually on specific topics. Now, these requirements are not written in a nice little paragraph in a single document. No-because that would be too easy. Rather, they must be pieced together by reviewing at least three different documents.

So, we will pull together those requirements for you and cite where we gathered this information from and where you can find it if you want to verify.

FTCA requires the following training every 12 months (SVP, Ch 21, Element e, Question 8):

1. Obstetrical Services (SVP, Ch 21.e.10, FTCA PAL). Required even for “health centers who do not provide OB services directly but may have contact with reproductive age patients for other clinical services.” This is generally understood to include all clinical staff who are credentialed and privileged (LIPs, OLCPs, and Other Clinical Staff).*** For more info, read this blog article.

2. Risk Management Training (for clinical staff) on Infection Control (SVP, Ch 21.e.11) and Sterilization (FTCA PAL)

3. Training (for all relevant staff) on HIPAA medical record confidentiality requirements (SVP, Ch 21.e.12)

4. Risk Manager Training (FTCA PAL)

5. Governing Board Risk Management training (FTCA SVP, p.9)

6. Medical Record Documentation (FTCA PAL)***

7. Follow-Up On Adverse Test Results (FTCA PAL)***

8. Provider-Specific Risk Training (FTCA PAL)***

9. High-Risk Services Training (HRSA SVP)***

10. Basic Life Support Training for all clinical staff (FTCA PAL, HRSA SVP)

The Risk Management Training Plan

Health centers are also required to develop an Annual Risk Management Training Plan that must outline training activities for the next calendar year. This plan should be developed “based on identified areas and activities of highest clinical risk for the health center and include detailed information” related to the health center’s tracking and documentation methods “to ensure that trainings have been completed by the appropriate staff, including clinical staff, at least annually”. The plan must include the required trainings above and outline the 1) Who is required to complete each training; 2) The source of the training; 3) The training delivery method and format, and 4) a brief description of the content covered in the training (FTCA Deeming Application, Step-By-Step Guide).

Documenting Completed Risk Management Training

Health centers are required to maintain documentation that all relevant staff have completed training in accordance with the health center’s annual risk management training plan. FTCA has provided an FTCA Educational Training Tracking Form that is required to demonstrate all planned trainings have been completed by the required staff. Again, all trainings must be completed during the calendar year (January 1-December 31).

For more information on how you can move your community health center from episodic to continuous HRSA compliance, contact the experts at RegLantern today!

***EDITS:

• Updated May 9, 2022 to include two additional trainings noted in the HRSA PAL 2022-01, which included “Medical Record Documentation”, “Follow-Up On Adverse Test Results”, and “Provider-Specific” trainings. The specific “Sterilization” training was also added to the infection control training to align with the HRSA PAL 2022-01.

• Updated May 27, 2022 to reflect the question added to Chapter 21 of the HRSA Site Visit Protocol, requiring “High Risk Services” training.

• Updated March 3, 2023 to reflect PAL 2023-01 where it states that risk management training for OB procedures is required even for “health centers who do not provide OB services directly but may have contact with reproductive age patients for other clinical services”. See RegLantern Blog Article here. Included BLS training in article for completeness. April 13, 2023 revision of HRSA SVP came into alignment with this FTCA training as well.

• Updated November 7, 2024 to reflect updated requirements around the required Annual Risk Management Training Plan and documentation of completion of trainings.