Primary Care Practices in Underserved Areas: FQHCs vs RHCs

1. Primary Practices in Underserved Areas: FQHCs and RHCs Elizabeth Morgan Burrows, JDChief Executive Officer Vermillion Parke Community Health Center October 27th, 2010

2. What are all these “HCs?” • FQHC – Federally Qualified Health Center • In hearing about the Affordable Care Act, Community Health Centers are all FQHC • RHC – Rural Health Clinic • State-funded CHC – Community Health Center • Indiana provides tobacco settlement money to fund state-funded CHCs. • FQHCs and RHCs can also be state-funded CHCs but not all of them are.

3. Currently in Indiana… • There are 47 state-funded Community Health Centers • 19 of the 47 are Federally Qualified Health Centers • 9 of the 47 are Rural Health Clinics • 62 Rural Health Clinics (9 are state-funded CHCs)

4. MUA/MUP and HPSA • To start an FQHC, the site must be located in a Medically Underserved Area or Population • To start an RHC, the site must be in a MUA/MUP or Health Professions Shortage Area

5. Starting an FQHC • FQHCs received funding under Section 330 of the Public Health Service Act. This funding is for operational expenses. • Program Assistance Letter 98-23 spells out all the federal requirements. • Must be located in an MUA or MUP. • New Access Point Funding is currently available through HRSA.

6. FQHCs • Non-profit entity • Governed by a consumer driven governing board (51% of the board members must be patients of the clinic) • Serve ALL patients regardless of their ability to pay through a Sliding Fee Scale • Must provide primary, behavioral, and dental services either on-site or through an arrangement for ALL patients

7. Benefits of an FQHC • Enhanced Medicaid and Medicare Reimbursement • Medical Malpractice under the Federal Tort Claims Act • 340B Drug Pricing • National Health Service Corps • Vaccines for Children

8. FQHC Look-Alike • Organization meets all requirements of a Section 330 grant. • No Grant funding for FHQC Look-Alikes. • Receives all other FQHC “benefits.”

9. State-Funded CHCs • Must meet a set of minimum standards outlined by the state • These standards are less stringent than FQHC standards • Must have a consumer-driven governing board

10. RHCs • Special Medicaid and Medicare reimbursement • Must be “certified” through CMS • Staffed at least 50% of the time with a midlevel provider • Can be for-profit or non-profit • Can be provider-based • Must be in a rural area and in a HPSA OR MUA/MUP

11. The Differences FQHCs RHCs Reimbursed at the Medicare All-inclusive rate by Medicaid and Medicare Can be for-profit or non-profit Can be owned by a hospital or other health system • Receive federal operational grant funding • Subject to many more federal regulations • Medicaid PPS Rate • Must be non-profit • Governed and owned by a community governing board; cannot be owned by a hospital or health system (exception for public Entities

12. Lessons Learned since I started an FQHC 3 years ago. If I knew then what I know now…

13. If I knew then what I know now – Community Support • You need to have community support and the support from your medical community. • You need individuals that are dedicated to making the health center a success. • You also need patients!

14. If I knew then… - Governing Board • The consumer-driven governing board is the integral foundation of the FQHC. Having board members that are committed to the health center’s mission is the key to success!

15. If I knew then… - Services • You don’t have to do everything on your own from the beginning! • Primary • Dental • Behavioral • Pharmacy • Outreach/Enabling Services

16. If I knew then… – Community Support • Without the support of Union Hospital Clinton and the entire Union Hospital Organization, we would not be the success that we are now.

17. If I knew then… – Rapid Growth • FQHCs are growing extremely quickly • In 2008, we completed over 3,500 encounters. • In 2009, over 8,000 encounters. • In 2010, we are expected to complete over 14,000 encounters.

18. If I knew then… - Policies and Procedures • FQHCs must have many policies and procedures established when they are started • QI plan • Credentialing Plan • After-hours Call Policy • Sliding Fee Scale implemented • Risk Management Plan • Recruitment and Retention Plan • And Many More

19. If I knew then… - The Deeming Process • FQHCs received medical malpractice coverage under the Federal Tort Claims Act. • Must be deemed for FTCA coverage. • Deeming process reviews your QI plan and the staff and board’s efforts for continual improvement.

20. If I knew then… • FQHCs are hard work! • The feds are actually there to help! • There are always more people to serve than the capacity that you have. • Other FQHCs and associations are there to help. • Serving members of my community is the most rewarding experience of my life.

21. Resources • www.hrsa.gov • www.isdh.in.gov • www.raconline.org • www.indianapca.org • www.indianaruralhealth.org

22. Elizabeth Morgan Burrows, JDVermillion-Parke Community Health Centeremorgan@vpchc.org765-828-1003 or 765-492-9042