Successfully Preparing Your OSV Patient Record Samples

During the Health Center Operational Site Visit (OSV) process, there are a number of patient record samples that are requested by the HRSA review team. These requests for documentation cover chapters 4, 7, 8, and 10 in the HRSA Site Visit Protocol. This is a part of the preparation process that can take a great deal of time and it's important to understand what the HRSA reviewers are looking for.

What is the purpose of the patient record review?

What HRSA is looking for in these patient record examples varies depending on the documentation requested, but, in short, HRSA wants to see:

• That health centers are providing all the services they say they are providing (as documented on HRSA Form 5A).

• “Closed-loop” documentation of services provided (from the moment the referral is provided to when the referral is completed, and when documentation and information is exchanged, to when the health center follows up with the patient).

Specifically, health centers are asked to provide:

• Documentation of Column I services if not observed during tours (Ch 4.a.3)

• Documentation of receipt of specific contracted services as indicated on Form 5A, Column II (3-5 examples) (Ch 4.a.4.4)

• Documentation of receipt of follow-up care and exchange in information from referrals to specific contracted services indicated on Form 5A, Column III (3-5 examples) (Ch4.a.5.3)

• Examples of after-hours calls and follow-up documentation (3 examples) (Ch7.d.9)

• Documentation of medical info related to hospital/ED visits (5-10 examples) (Ch8.c.3.1)

• Documentation of follow-up actions based on info exchanged (5-10 examples) (Ch8.c.3.2)

• Examples of patient records with a clinic visit note or summary of care (5-10 examples) (Ch10.e.11-12)

How do we provide patient record examples to the HRSA Reviewers?

Health centers can choose one of two methods for sharing their patient record examples with the HRSA team during their Operational Site Visit (OSV): Uploaded and redacted screenshot examples or a live patient record review.

If the health center chooses a live patient record review, the clinical team should complete the following steps:

• Access RegLantern’s Record Gathering Tool, print it off, and use it as a guide to gather examples. (This tool is available to health centers who have created a user login on RegLantern’s platform. If you would like to sign up for free, click here.).

• Look at the various columns across the top of the tool and note what HRSA is looking for, the requirement citation in the HRSA Site Visit Protocol (which indicates the chapter, element, and question number where this requirement is located in the HRSA Site Visit Protocol).

• Note how many examples are requested in parentheses (i.e., 3, 5-10, etc.).

• Locate patient record examples that have occurred in the 12 months before your anticipated OSV date that meet the criteria listed (i.e. If your OSV date is scheduled for June 1 this year, medical records need to document care that was delivered since June 1 of the prior year).

• As document examples are located, record in each row on the RegLantern Record Gathering Tool the medical record number (MRN) and the date of service (DOS) for each example.

• Evaluate each example and mark an “X” in each column on the RegLantern Record Gathering Tool where it may serve as documentation for HRSA-required samples. One sample can and should be used for multiple examples of demonstrated compliance.

Record enough medical records so that each column has the minimum number of required examples (as indicated in each column).

Health centers may choose to provide samples of patient records before or during the site visit. If patient records will be provided during the site visit (through a live record review), this should be communicated before the site visit (typically during the HRSA Pre-Site Visit Call with the review team which is usually held approximately six weeks before the scheduled OSV date) to avoid any disruption or delay in the site visit process (HRSA SVP, Chapter 10).

When it’s time for your live patient record review during your OSV, the reviewer will ask to see an example of certain services. You can then reference the RegLantern Record Gathering Tool and associated MRN and Date of Service, open that file in your EHR, and show the reviewer the example while they observe over your shoulder.

If the health center chooses to upload samples of the medical records, they must have all protected health information (PHI) fully redacted. It is still recommended that the health center use the RegLantern Record Gathering Tool and complete all of the steps listed above for the live record review then redact and upload the samples for the reviewers.

Most health centers do not have a great deal of trouble with this part of the OSV. However, it is critical that all health centers plan ahead and organize themselves so they are prepared to demonstrate compliance to the HRSA review team.