Ready For Your FTCA Application Submission in 2025?

So, you’re done submitting your UDS data for the year and you’re 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 releases an updated “Program Assistance Letter” or “PAL”. This is 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 2025 application cycle is PAL 2025-01. According to this PAL, the FTCA Application in HRSA’s Electronic Handbooks (EHBs) will open on February 27, 2025, and will close June 27, 2025, 11:59 PM, ET.

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.

[NOTE: With the new presidential administration removing documents from agency websites, this document was removed sometime at the beginning of February 2025. We will update this blog post if and when it is restored to the website.]

As you prepare to submit your FTCA Application, we recommend you do the following:

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. 2025’s PAL 2025-01 can be read here.

• Plan to submit your application at least one month before the application closes (This year that date is May 27, 2025). This will allow ample time to submit your application and lower the stress level for your team.

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 the EHBs Application opens in comparison to the current PAL, but following the current structure as outlined in the PAL will help you to be ready if we update the platform after the EHBs Application opens. Name the review something like “FTCA Application Prep 2025-02-18” so you know the preparation is being completed based on the current PAL as of the date you created the new review instance.

• 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! This year, we are providing FTCA Application Mock Reviews to make sure your application looks great before submitting it to HRSA. Contact us today to learn more!

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. These should be completed by December 31, 2024.

• Health Centers risk managers should complete their annual risk management training. Again, this should be done by December 31, 2024.

• 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 (2024). 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. However, the health center may present this report in the new year (2025); Our RegLantern team recommends you present this report to the board of directors in February or March of each year.

• Check out RegLantern’s blog post on the annual risk management to the board.

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 that 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).

• Allow plenty of time to update the Credentialing List. Though last year’s list will carry over to this year’s application, health center leaders must add any health center staff who joined the organization since the last application and remove any who left the organization. They must also update the most recent credentialing and privileging dates for all staff in the Credentialing List. This task is quite time-intensive, so allow plenty of time to update.

• Check out RegLantern’s blog posts on the annual risk management to the board.

Key 2025 FTCA Changes

Last year, HRSA announced a transition year as they switched to a reporting period of January 1 to December 31 of the previous calendar year. There was some grace granted during this transition year. However, for applications submitted in 2025, all Risk Management activities must be reflective of the new calendar year reporting period.

The reality is that probably some reading this may be missing some of the required elements, and some of the required activities may have been overlooked (Quarterly Risk Management Assessments) or fallen outside the 2024 calendar year (Risk Management Training completion). Though this is not ideal, health centers who find themselves in this situation must 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. Particularly, they will be looking to ensure systems and plans are in place to ensure the health center gets back on track and does not miss FTCA-required activities in the future.

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? Are you interested in our FTCA Application Mock Reviews? Contact us here and we’ll be happy to help! We are confident our tools and services will make this year’s application process your easiest one yet!