So, you want to be an FQHC Look-Alike? Here are 8 things you need to know

So, you want to be an FQHC Look-Alike?

A Federally Qualified Health Center (FQHC) and an FQHC Look-Alike are designations approved and overseen by the Health Resources and Services Administration (HRSA) Bureau of Primary Care, a branch of the U.S. Department of Health and Human Services. An FQHC designation allows community-based health centers to receive higher cost-based reimbursement for providing primary health services to Medicaid and medically uninsured residents of communities who are unable to pay the full cost of receiving services. FQHCs also qualify for additional opportunities and privileges, such as supplemental grant funding, 340B drug pricing, free and low-cost childhood vaccines, National Health Service Corp designation whereby FQHCs can employ providers who in return get their public schools loans forgiven, and the Federal Torts Claims Act (FTCA), whereby the community clinics receive medical malpractice insurance for their employers.

A clinic can only become a full FQHC, which includes an annual grant and FTCA, through a competitive application process that becomes available from time to time through a HRSA formal Notice of Funding Opportunity (NOFO) process. However, a clinic can become an FQHC Look-Alike, which does not receive an annual grant or FTCA, though it will receive most other benefits including a higher cost-based reimbursement rate. This is vital for financial feasibility when working in a community with a high proportion of lower income residents! The FQHC Look-Alike application can be completed at any time; however, the community clinic must ensure the same level of compliance with FQHC requirements.

Here are eight key facts you should know before you begin the process to become an FQHC Look-Alike:

  1. It is all about “compliance.” To become an FQHC Look-Alike, your organization has to comply with all 19 HRSA health center program requirements (see HRSA’s FQHC Compliance Manual HTML or PDF). It is a compliance application whereby you are demonstrating compliance with all 19 requirements which must be in place at the time of application submission, and will be verified at an Operational Site Visit (OSV).
  1. It takes engagement and a responsive team. The FQHC Look-Alike program will require a significant change in the way your organization must operate. This can include changes to your current quality improvement practices, financial protocols, board authority and oversight, among other items. In order to be successful, it is imperative to have an engaged team of staff and board members who are actively working with your consultant on the application, and as well as implementing program chances to ensure compliance before application submission.
  1. You lose personal control over the organization. You are required to have a governing board of directors for the organization, and more than one-half (51%) of its members must be patients of the health center. This follows the conventional “community health center” patient-directed organizational model, which has proven to be effective in ensuring that services are responsive to the community’s needs.  The organization’s commitment to delivering quality care for underserved community members is a hallmark of the FQHC program with the consumer majority board of director’s overseeing its services and programs
  1. You must provide access to 21 required primary care services. These services include basics such as general primary medical care, gynecological care, and immunizations. They must also include enabling services such as case management, transportation, language translation, and more (see HRSA’s list of Services PDF and Service Descriptors PDF). Services can be provided directly by the health center or by contractual agreement or referral to another provider. Look-Alikes can also provide additional health services, such as optometry, behavioral health, alternative medicine, and more, but only after initial designation is approved for primary care services.
  1. You must account for your income and expenses. To provide taxpayer dollars to reimburse your costs for providing quality health services, HRSA wants to know that you are operating in a fiscally responsible manner. This includes submitting an annual operating budget (see HRSA’s Look-Alike Annual Certification resources HTML and instructions PDF), and also reporting cost-based charges and actual revenues and expenses in your annual Uniform Data Systems (UDS) Performance Report (see HRSA’s UDS Resources HTML and Manual PDF) for the prior calendar year. Details include cost-based charges for services (even if you do not expect full payment for these services), amounts collected (including co-pays, capitation payments, federal reconciliation/wrap-around payments, and more), and amounts written off via sliding fee discounts or as bad debt. Reporting this information accurately is a common challenge for new Look-Alikes, so let GBA help you prepare.  You are also required to engage an independent auditor for annual audit for prior year’s revenues and expenses.
  1. This isn’t “just an application.” GBA can write a compliant application for you. However, at the time the application is submitted to HRSA, your organization MUST BE compliant. HRSA will schedule your OSV soon after submittal to ensure your organization is operating as described in your application (see HRSA’s Site Visit Protocol HTML or PDF). After the site visit, HRSA will provide you with a report that of its site visitors’ findings and conditions that must be met for your Look-Alike designation to be approved. While some are small changes, others are not, and if you do not comply, your application will be denied. While we will advise you on HRSA expectations, as this information is included in your application, we have seen some applications declined because the site visitors were unable to confirm that the required policy or practice had been implemented.
  1. Your consultant is not allowed to be present for your OSV. Therefore, you must be able to demonstrate compliance by yourself when the time comes. GBA will do everything that can be done to prepare you for the OSV during application development and after submission. This includes conducting a mock site visit, and meeting with board members and health center staff to ensure readiness. HRSA has a lot of resources to help you prepare (see HRSA’s Site Visit Protocol HTML or PDF).
  1. Ultimately, your success is up to you. GBA understands that this process and application may seem daunting. It is our job to walk you through every step of the process, and to let you know what you need to do within your organization to submit a compliant application that reflects your current practices. You and your board must put into place compliant policies, formulate or change bylaws, and implement required programs, practices, and services for your organization. While we, as your consultant cannot do these things for you, we will work with you hand-in-hand on everything you must do to ensure compliance and to successfully be awarded FQHC Look-Alike designation.

GBA would be happy to provide a free consultation to determine your health center’s readiness with the Look-Alike program. We also offer support on Internal Revenue Service (IRS) applications, and clinic licensing, which are required steps prior to submitting the Look-Alike application. Please contact Gary Bess at gary@garybess.com or Katie Strautman at katie@garybess.com for more information.

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