SVP Update: Form 5A Contracts & Agreements

With the May 27, 2021 update of the HRSA Site Visit Protocol, health centers will see some changes in regard to contracts and agreements associated with Form 5A.

Documentation of Contracted/Referral Services in Health Center Record

First, Chapter 4, “Required and Additional Health Services” now contains some clarified language about how the health center is expected to demonstrate compliance around documentation of the service in the medical record. The question (SVP, Ch. 4, Element a., Question 2.3) now reads:

“Do the health center’s contracts/agreements or any supporting internal procedures document how information regarding the service(s) will be provided to the health center for inclusion in the patient’s health center record?”

The key difference is the addition of the, “…or any supporting internal procedures…” verbiage. This clarification now allows the health center to include this language in health center documentation policies or procedures, rather than working with third-party service providers to include this language in the contract/agreement.

Referral Management & Tracking Documentation

Next, Chapter 4, “Required and Additional Health Services” now contains some clarified language about how the health center is expected to demonstrate compliance around documentation of plans to track services provided by referral partners. The question (SVP, Ch. 4, Element a., Question 3.2) now reads:

“Do the health center’s formal written referral arrangements or other documentation (for example, health center standard operating procedures) include provisions that address the manner by which referrals will be made and managed as well as the process for tracking and referring patients back to the health center for appropriate follow-up care (for example, exchange of patient record information, receipt of lab results)?”

The key difference is the addition of the, “…or other documentation (for example, health center standard operating procedures)…” language. This clarification now allows the health center to include this language in health center referral tracking policies or procedures, rather than working with third-party service providers to include this language in the contract/agreement.

Credentialing and Privileging of Contracted or Referral Providers

Then in Chapter 5, “Clinical Staffing” now contains some clarified language about how the health center is expected to demonstrate compliance around assurances that third-party service providers are appropriately credentialing and privileging their clinical staff. Though the questions (SVP, Ch. 5, Element f., Questions 12 and 13) have not changed, additional notes and guidance have been provided (SVP, p. 26):

“Examples of demonstrating credentialing and privileging for contracted or referral providers could include assurance that the health center has reviewed:

• The contracted organization’s credentialing and privileging processes for providers, such as physicians, pharmacists, and dentists;

• The contracted organization’s documentation from a nationally recognized accreditation organization; or

• The contracted laboratory’s documentation of Clinical Laboratory Improvement Amendments (CLIA) compliance.”

Practically, this is what many reviewers were doing. However, there was some reviewer variation in what was deemed acceptable documentation. This additional clarification is helpful in providing specific examples of documentation that may be provided to demonstrate compliance.

Though it is still a best practice to include service EHR documentation, referral tracking language, and credentialing/privileging assurances in the contracts or agreements, these changes allow health centers a greater number of options for demonstrating compliance if contract changes are not an option.