Iowa Association of Rural Health Clinics
RHC Survey and Certification
October 1, 2014
10:45 a.m. - 11:45 a.m.
or subtitle
JeffDate
Bramschreiber,
CPA, Partner
Wipfli Health Care Practice
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Discussion Topics
I.
RHC Survey and Certification Overview
II. Discussion of Recent Surveys
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RHC Survey & Certification Overview
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RHC Survey Requirement
The rural health clinic survey is a key component of the
RHC certification process for Medicare and Medicaid.
RHC certification can be obtained through the state
agency, or through accreditation organization with deemed
status for Medicare, such as the American Association for
Accreditation of Ambulatory Surgery Facilities (AAAASF) or
The Compliance Team.
An on-site inspection is performed as part of the initial RHC
certification process. Periodic re-inspections are performed
thereafter.
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RHC Survey Resources
1. Starting a RHC – A How-To Manual
2. CMS-30 (Rural Health Clinic Survey Report)
3. State Operations Manual – Appendix G
4. Common RHC Survey Deficiencies
5. AAAASF Self-Survey Materials
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RHC Survey Resources
Table of Contents
Starting a RHC – A
How-To Manual
Chapter 1
Overview of the RHC Program
Chapter 2
Getting Started - Does Your Site Qualify?
Chapter 3
Feasibility Analysis - Is The RHC Program For
You?
Chapter 4
How to File the RHC Application
Chapter 5
Preparing for the RHC Certification Inspection
Chapter 6
Completing the Cost Report
Chapter 7
RHC Coding and Billing Issues
Appendix A
State Survey and Certification Agencies
Appendix B
State Offices of Rural Health
Appendix C
Criteria for Designation as a HPSA or MUA
Appendix D
Sample Policy and Procedures Manual
Appendix E
Other Resources
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RHC Survey Resources
CMS-30 (Rural Health Clinic Survey Report)
CODE
YES NO
N/A
EXPLANATORY STATEMENTS
J66
■ MET
■ NOT MET
VII. §481.10 Patient health records.
J67
■ MET
■ NOT MET
(a) Records system.
J68
(1) The clinic maintains a clinical record system in accordance with
written policies and procedures.
J69
(2) A designated member of the professional staff is responsible for
maintaining the records and for ensuring that they are completely and
accurately documented, readily accessible, and systematically organized.
J70
(3) For each patient receiving health care services, the clinic maintains a
record that includes, as applicable:
(i) identification and social data, evidence of consent forms, pertinent
medical history, assessment of the health status and health care needs of
the patient, and a brief summary of the episode, disposition, and
instructions to the patient;
(ii) Reports of physical examinations, diagnostic and laboratory test
results, and consultative findings;
(iii) all physician’s orders, reports of treatments and medications and
other pertinent information necessary to monitor the patient’s progress;
(iv) signatures of the physician or other health care professional.
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RHC Survey Resources
State Operations Manual – Appendix G
VII. PATIENT HEALTH RECORDS (42 CFR 491.10)
A. Records System.--The clinic is to maintain patient health records in accordance with its written
policies and procedures. These records are the responsibility of a designated member of the clinic’s
professional staff and should be maintained for each person receiving health care services. All records
should be kept at the clinic site so that they are available when patients may need unscheduled medical
care.
Examine a randomly selected sample of health records to determine if appropriate information, as related
in J70 of the SRF and 42 CFR 491.10(a)(3), is included. This listing is the minimum requirement for
record maintenance. If deficiencies are found while reviewing the records, review additional records to
determine the prevalence of these deficiencies. Record on the SRF the number of records reviewed and
deficiencies found, if any, and as questions arise concerning the records, discuss them with the person
responsible for record maintenance.
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RHC Survey Resources
Common RHC Survey Deficiencies
Code
Section
Regulation
J70
491.10(a)(3)
For each patient receiving health care services, the clinic
maintains a record that includes, as applicable: i. Identification
and social data, evidence of consent forms, pertinent medical
history, assessment of the health status and health care needs of
the patient, and brief summary of the episode, disposition, and
instructions to the patient; ii. Reports of physical examinations,
diagnostic and laboratory test results, and consultative findings;
iii. All physician’s orders, reports of treatments and medications
and other pertinent information necessary to monitor the
patient’s progress; iv. Signatures of the provider or other health
care professional.
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RHC Survey Resources
Common RHC Survey Deficiencies (cont.)
Code
Section
Regulation
J22
491.6(b)(1)
The clinic has a preventive maintenance program to
ensure that all essential mechanical, electrical and patientcare equipment is maintained in safe operating condition.
J58
491.9(b)(4)
These policies are reviewed at least annually by the group
of professional personnel as required under 491.9(b)(2),
and reviewed as necessary by the clinic.
J57
491.9(b)(3)(iii) The policies include guidelines for the medical
management of health problems, which include the
conditions requiring medical consultation and/or patient
referral, the maintenance of health care records, and
procedures for the periodic review and evaluation of the
services furnished by the clinic.
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RHC Survey Resources
Common RHC Survey Deficiencies (cont.)
Code
Section
Regulation
J56
491.9(b)(2)
Patient care policies are developed with the advice of a
group of professional personnel that includes one or more
physicians and one or more physician’s assistants or nurse
practitioners. At least one member of the group is not a
member of the clinic staff.
J61
491.9(c)(2)
The clinic provides basic laboratory services essential to
the immediate diagnosis and treatment of the patient,
including: i. Chemical examinations of urine by stick or
tablet methods or both (including urine ketones); ii.
Hemoglobin or hematocrit; iii. Blood sugar; iv. Examination
of stool specimens for occult blood; v. Pregnancy tests;
and vi. Primary culturing for transmittal to a certified
laboratory.
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RHC Survey Resources
Common RHC Survey Deficiencies (cont.)
Code
Section
Regulation
J23
491.6(b)(2)
The clinic has a preventive maintenance program to
ensure that drugs and biologicals are appropriately stored.
J62
491.9(3)
The clinic provides medical emergency procedures as a
first response to common life-threatening injuries and
acute illness, and has available the drugs and biologicals
commonly used in life saving procedures, such as
analgesics, anesthetics (local), antibiotics, anticonvulsants,
antidotes and emetics, serums and toxoids.
J47
491.8(b)(2)
Physician responsibilities: In conjunction with the
physician’s assistant and/or nurse practitioner member(s),
the physician participates in developing, executing and
periodically reviewing the clinic’s written policies and the
services provided to Federal program patients.
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RHC Survey Resources
Common RHC Survey Deficiencies (cont.)
Code
Section
Regulation
J51
491.8(c)
Physician’s assistant and the nurse practitioner
responsibilities. The physician’s assistant and the nurse
practitioner members of the clinic’s staff: i. Participate in
the development, execution and periodic review of the
written policies governing the services the clinic furnishes;
ii. Provide services in accordance with those policies; iii.
Arrange for, or refer patients to, needed services that
cannot be provided at the clinic; iv. Assure that adequate
patient health records are maintained and transferred as
required when patients are referred; and v. Participate with
a physician in a periodic review of the patient’s health
records.
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RHC Survey Resources
Common RHC Survey Deficiencies (cont.)
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RHC Sources of Information
 42 CFR §491 (RHC Regulations)
 Appendix G
Interpretive Guidelines – Rural Health Clinics
State Operations Manual (HCFA-Pub. 7)
 Starting a RHC – A How To Manual
www.bphc.hrsa.dhhs.gov
www.narhc.org
www.nrharural.org
 AAAASF/RHC - RHC Medicare Accreditation
www.rhcaccreditation.org
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Discussion of Recent Surveys
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RHC Survey Discussion
Participants are asked to share their experience with a
recent RHC survey.
•
•
•
•
•
Facility name, location, and number of providers.
How long has the location been a certified RHC.
When was the survey completed?
Was the recent survey an initial or a re-certification?
Who did the survey (state agency or deemed
accreditation organization)?
• How long did the survey last?
• How many surveyors participated in the survey?
• What did you learn?
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Questions
?
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For More Information
This presentation was prepared by:
Jeff Bramschreiber, CPA
Partner, Health Care Practice
Wipfli LLP
469 Security Blvd.
Green Bay, WI 54313
920.662.2822
jbramschreiber@wipfli.com
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