Ready For Your FTCA Application Submission in 2024?

So, you’re done submitting your UDS data for the year and you are now turning your focus to this year’s Federal Tort Claims Act (FTCA) application…you may be asking yourself, “What do I need to do first?”.

Each January or February, HRSA will release an updated “Program Assistance Letter” or “PAL”. This will be a critical document that will provide important information on the requirements for this year’s redeeming application. Keep an eye out for each year’s FTCA PAL here. The PAL for the FTCA 2024 application cycle is PAL 2024-03. HRSA has released a new document (FTCA Deeming Application Step by Step Guide) that is a helpful companion to the PAL that every health center should review while they are waiting for the HRSA/FTCA PAL to be released each year.

But until that happens, we recommend you make sure you are ready to hit the ground running as soon as each year’s FTCA PAL is released. We recommend you do the following in the meantime:

General: 

• Read HRSA’s FTCA Deeming Application Step-by Step Guide (It’s long, so get started early and chip away at it day-by-day!).

• Read the FTCA PAL when released each year. 2024’s PAL 2024-03 can be read here.

RegLantern Platform:

• For those who are RegLantern customers, we recommend you create a new review in our FTCA Application Tool. It’s important to remember that the questions or other details may change slightly when we receive official guidance in the FTCA PAL but following last year’s review will help you to be ready when we update the platform with the new application. Name the review something like “FTCA Application Prep 20xx” so you know the preparation is being completed on the previous year’s application.

• Go through the platform and review the questions, making sure all the required documentation examples are updated and uploaded to the RegLantern platform.

• Need help getting ready for this year’s FTCA application? We’re here to help! Contact us today!

Training: 

• Make sure the health center’s Risk Management Training Plan contains all the required elements and training. Check out this RegLantern blog post on FTCA Required Trainings.

• Health Centers should complete their risk trainings (OB, Infection Control, HIPAA, and Areas of High Risk) as they are defined in the previous year’s Risk Management Training Plan. See our previous blog posts on OB Risk Management Training and general FTCA training requirements for more information.

• Health Centers risk managers should complete their annual risk management training.

• Make sure all Risk Management Trainings the health center set to be completed in the previous calendar year have been completed as indicated in the health center’s Risk Management Training Plan.

• Health centers are being asked to complete a new FTCA Educational Training Tracking Form (Fillable PDF or Excel Version). Health centers will enter information on one completed training for each required topic: obstetrics, infection control, HIPAA, and areas of high risk. Health centers will then download and use the provided FTCA Educational Training Tracking Form to document attendance and training completed for each staff member. All training must cover the period from January 1 to December 31 of the previous calendar year of submission of the application. If different trainings are required for different staff, health centers will be asked to complete separate FTCA Educational Training Tracking Forms for each additional course to document completion. The completed forms will then need to be uploaded to the FTCA Application in the Electronic Handbooks (EHBs). Previously, health centers were permitted to upload completion reports from their Learning Management System (LMS) software. This is no longer permitted and will be considered non-compliant if anything other than the designated FTCA Educational Training Tracking Form is uploaded.

Risk Management Policies and Procedures:

• Review the health center’s tracking procedures for referrals, diagnostics, and hospital admissions.

• Check out RegLantern’s blog post on these policies.

Quarterly Risk Management Assessments:

• Health Centers should ensure they have completed Quarterly Risk Management Assessments and be prepared to upload these to the FTCA Application.

• Gather documentation of the health center’s Quarterly Risk Management Assessments completed in the previous calendar year.

Annual Report to the Board and Key Management Staff: 

• Health Centers should make sure they have provided a report to the board and key management staff that details risk management activities, the status of the health center’s progress towards meeting the established risk management goals, and planned activities for the upcoming calendar year. The report must cover the period from January 1 to December 31 of the previous calendar year of submission and must be reflective of the activities related to risk from the previous calendar year.

Credentialing and Privileging: 

• Health Centers should thoroughly review their operating procedures to ensure that their process in place for both initial and recurring credential reviews for all clinical staff Licensed Independent Practitioners (LIP), Other Licensed or Certified Practitioners (OLCP) and Other Clinical Staff (OCS) includes all the required elements as outlined in the FTCA application and other policy guidance. 

• Health Centers should ensure that all clinical staff (LIPs, OLCPs, and OCS) review their credentials and privileges and they have been credentialed within the last two years at the time of date of the submission of the FTCA application (Usually May or June each year).

Key 2024 FTCA Changes We Know Already

We have learned that HRSA is going to be requiring health centers to complete their CY 2023 Risk Trainings for this year’s applications and that applications submitted in 2024 will assess whether trainings for 2023 (January 1 – December 2023) were completed. This will affect those health centers whose Risk Management Training Plans or Risk Management reporting cycles overlap two calendar years (July 1, 2023 – June 30, 2024). Previously, health centers were allowed to set their own Risk Management reporting calendars however they wished; this year, that will be changing.

However, HRSA understands that health centers may have previously followed a different reporting period and there may be an overlap between the information submitted in this year's application and the information submitted last year for 2023. 

For applications submitted in 2024, you may include an explanation for any issues related to the reporting period, and the explanations will be reviewed and considered by FTCA on a case-by-case basis.

HRSA will consider the facts, the health center explanations, and the documents provided to determine compliance considering the transition period. For application submission in 2025, all health centers should be fully transitioned to the new reporting period (January 1 to December 31, prior to the submission year).

Keep an eye on RegLantern’s communications as we will share updates from HRSA as soon as we receive them.

Are you interested in receiving a free trial of RegLantern’s FTCA application tools for this year’s FTCA deeming cycle? Contact us here and we’ll be happy to get you set up right away! We are confident our tools and services will make this year’s application process your easiest one yet!