Overview of Site Visit Process Ryan White HIV/AIDS Program Part C, D, and F-Dental Department of Health and Human Services Health Resources and Services Administration HIV/AIDS Bureau Division of Community HIV/AIDS Programs Admin Webinar Goal To increase the knowledge of Consultants and Project Officers on how to effectively assess and report on the HRSA/HAB/DCHAP’s Ryan White HIV/AIDS Program Part C, D, and F-Dental grantees provision of comprehensive, high quality healthcare for people living with HIV/AIDS, compliance with legislative and programmatic requirements, and the National HIV/AIDS Strategy. Webinar Objectives By the end of the webinar, participants will: • Become familiar with all applicable Federal statutes and regulations relative to the administration of grants. • Increase knowledge of how to properly use the Site Visit Assessment Tool. • Compare and contrast the Ryan White HIV/AIDS Program Parts A,B,C,D, and F, and Minority AIDS Initiative. • Describe the reasons for conducting a site visit and how to prepare for pre and post site visit activities. • Identify “What’s New?” with the 2013 Site Visit Assessment Tool. • Increase knowledge of the site visit process. • Apply tools to write a concise and comprehensive report. Webinar Outline • Overview of HRSA/HAB • Authorities that Govern Site Visits • Ryan White HIV/AIDS Program Parts A,B,C,D, and F, and MAI • Monitoring Site Visits • Site Visit Roles and Responsibilities • Team Member Professional Standards • Site Visit Assessment Tool • Site Visit Reporting Criteria • Tips for Writing a Concise and Comprehensive Report Health Resources and Services Administration (HRSA) Vision Healthy Communities, Healthy People Mission To improve health and achieve health equity through access to quality services, a skilled health workforce, and innovative programs. HIV/AIDS Bureau Vision Optimal HIV/AIDS care and treatment for all. Mission Provide leadership and resources to assure access to and retention in high quality, integrated care and treatment services for vulnerable people living with HIV/AIDS and their families. Authority The site visit process is governed by: • • • • • Ryan White HIV/AIDS Legislation Title XXVI of the Public Health Service Act HAB Policy Notice National HIV/AIDS Strategy Funding Opportunity Announcement Ryan White HIV/AIDS Legislation Congress enacted the Ryan White Comprehensive AIDS Resources Emergency (CARE) Act in 1990 to improve the quality and availability of care for low-income, uninsured, and underinsured individuals and families affected by HIV disease. The CARE Act was amended and reauthorized in 1996, 2000, and 2006; in 2009 it was reauthorized as the Ryan White HIV/ AIDS Treatment Extension Act of 2009 (Public Law 111–87). Ryan White HIV/AIDS Program Administered by the U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA), HIV/AIDS Bureau (HAB), the Ryan White HIV/AIDS Program works with cities, states, and local community based organizations to provide services to over 559,000 people each year who do not have sufficient health care coverage or financial resources to cope with HIV disease. The majority of Ryan White HIV/AIDS Program funds support primary medical care and essential support services. A smaller but equally critical portion is used to fund technical assistance, clinical training, and research on innovative models of care. Title XXVI of the Public Health Service Act- examines the authority of the government at various jurisdictional levels to improve the health of the general population within societal limits and norms. HAB Policy Notices- provides updates from HAB regarding clarification of legislation and policies. Funding Opportunity Announcement (FOA)- explains the availability of a Federal grant funding opportunity and application process and is released through Grants.gov. National HIV/AIDS Strategy Goals Increasing access to Reducing new HIV care and improving infections health outcomes for PLWHA Reducing HIV-related disparities and health inequities Achieving a more coordinated national response to the HIV epidemic Ryan White HIV/AIDS Program Parts A,B,C,D, and F, and the Minority AIDS Initiative Ryan White HIV/AIDS Program Part A • Metropolitan Areas affected by HIV/AIDS Part B • States and US Territories • AIDS Drug Assistance Program (ADAP) Part C • Early Intervention Services and Capacity Development Part D • Women, Infants, Children and Youth (Part D) Part F • Dental, Education/Training, Planning, Capacity Development and Demonstrations, Minority AIDS Initiative Ryan White HIV/AIDS Program Administration Part A • Division of Metropolitan HIV/AIDS Programs Part B • Division of State HIV/AIDS Programs Part C, D and F Dental • Division of Community HIV/AIDS Programs Ryan White HIV/AIDS Program Part A • Emergency assistance to Eligible Metropolitan Areas (EMAs) and Transitional Grant Areas (TGAs) that are most severely impacted by the HIV/AIDS epidemic • Award made to Chief Elected Official • Funding allocations determined by Planning Council • Part A funds distribution: • 2/3 by formula – based on the number of living cases of HIV (non AIDS) and AIDS • 1/3 supplemental – competitive grant process Ryan White HIV/AIDS Program Part B • Base Grant - Provides grants to all 50 States, the District of Columbia, Puerto Rico, Guam, U.S. Virgin Islands, 6 Pacific jurisdictions to pay for care for people living with HIV/AIDS • For jurisdictions with >1 percent of nation’s HIV/AIDS cases, match required $1 state: $2 federal • Funds distributed by formula based on HIV/AIDS cases • Award made to Chief Elected Official • AIDS Drug Assistance Program (ADAP) pays for: • Medications to treat HIV disease • Insurance continuation for eligible clients • Services that enhance access, adherence, and monitoring of drug treatment Part C EIS Overview • Purpose: To provide comprehensive continuum of outpatient HIV primary care in a service area. • Required Services: • • • • HIV counseling, testing, and referral Medical evaluation and clinical care Other primary care services Referrals to other health services • Medical Model of Care: • Assess • Treat • Refer Part D WICY Overview Purpose: To provide family-centered primary medical care to women, infants, children, and youth (WICY) living with HIV/AIDS when payments for such services are unavailable from other sources. Ryan White HIV/AIDS Program Part F / Dental Dental Reimbursement Program • Expands access to oral health care for PLWHA while training additional dental and dental hygiene providers Community Based • Provides oral health services to PLWHA via cooperative projects with communityDental Partnership Program based providers of oral health services Minority AIDS Initiative (MAI) • Goal: To help reduce the disproportionate impact of HIV/AIDS and address disparities by: • Increasing the number of persons from racial and ethnic minority populations receiving HIV care, and • Increasing the number of persons from racial and ethnic minority populations who stay in care. • MAI funds awarded are noted under the grant specific terms section of the Notice of Award (NoA) which establishes the final funding for the budget period. Ryan White HIV/AIDS Treatment Extension Act of 2009 (Public Law 111-87,October 30,2009), §2693 Monitoring Site Visits DCHAP Site Visits Types of Site Visits Description Comprehensive •Conducted to review a Program’s ability to meet the legislative and programmatic requirements of the Ryan White HIV/AIDS Program •Newly awarded and established grantees who have not had a site visit within the last five years are a priority Diagnostic •Conducted to identify and clarify any programmatic deficiencies for grantees who are exhibiting challenges within one or more of the three core areas: clinical, fiscal or administrative Technical Assistance •Conducted to offer appropriate support to enhance a grantee’s capacity to provide high quality, cost competitive health care and services Ryan White HIV/AIDS Program Compliance Monitoring Monitoring Calls HRSA/HAB conducts ongoing review and monitoring of grantees Review of RW Programmatic Reports Review of Fiscal Reports Comprehensive Site Visits Diagnostic Site Visits Why Do We Conduct Site Visits? 1. Support DCHAP’s mission to provide grantee oversight in the delivery of comprehensive high quality HIV primary and oral health care. 2. Verify the grantee’s program is in compliance with the Ryan White Legislative & Programmatic requirements. 3. Ensure highest quality HIV clinical care and compliance with HHS Guidelines. 4. Ensure administrative and fiscal integrity. 5. Identify technical assistance needs to address any program deficiencies. What Can “Trigger” a Site Visit? - Need for an initial site visit for newly awarded grantee or comprehensive site visit for established grantee - Low score on recent competitive application or lack of progress reflected within non-competing report - Habitual and problematic staff turnover for grantee - Lack of communication with Project Officer - Continually failing to meet work plan objectives - A sense on the part of the Project Officer/Branch Chief that “something’s just not right” with the grantee’s program - Media attention - Known financial problems - Problematic spend-down patterns and/or multiple years with unobligated balances - Draw down restrictions Goal of Site Visit Timeline Minimum of 10 Weeks Prior to Scheduled Site Visit Consultants are identified and site visit materials are emailed to Consultants Minimum of 8 Weeks Prior to Scheduled Site Visit Project Officer Confirms Date and Time of Pre-Site Visit Conference Call with Consultants and Grantee Minimum of 4 Weeks Prior to Scheduled Site Visit Pre-Site Visit Conference Call Held with the Project Officer, Consultants, and Grantee Goal of Site Visit Timeline continued Within 1 Week of Completion of Site Visit Site Visit Report Submitted by Consultants to Team Leader Within 2 Weeks of Completion of Site Visit Site Visit Report Submitted by Team Leader to Project Officer Within 4 Weeks of Completion of Site Visit Site Visit Report Approved by Project Officer, Branch Chief, Clinical Reviewer, and Deputy Director of DCHAP By 4 Weeks Following Completion of Site Visit Project Officer Releases Completed Site Visit Report to Grantee Pre-Site Visit Prep 1. Pre-Site Visit Preparation • Copy of most recent applicable Funding Opportunity Announcement (FOA) • Most recent Competing Application and Non-Competing Progress Report • Most recent Ryan White Services Report (RSR) • Three most recent Federal Financial Reports • Current line item budget and justification • Copies of any previous Site Visit Reports (as applicable) • Most recent A-133 Audit 2. Team Pre-Site Visit Conference Call • Team Leader, Consultant Team Members and Project Officer. 3. Pre-Site Visit Conference Call with the Grantee How Does Grantee Prepare for the Site Visit? 1. Extensive instructions from their Project Officer 2. Materials provided to grantee: • Site Visit Assessment Tool • Pre-Site Visit Conference Call Agenda • List of “Materials to be Available” for review on-site • Sample Site Visit Agenda • “Site Visit Evaluation Form” 3. Site Visit Agenda jointly developed with Team Leader Site Visit Roles and Responsibilities Pre-Site Visit Activities Role of Project Officer • Internally initiates the site visit within HAB • Establishes the site visit date, Pre-Site Visit Conference Call(s), and prepares packet • Communicates with the Team the purpose of the site visit Pre-Site Visit Activities Role of Team Leader Confirms travel arrangements, Makes him/herself available by arrival and departure times with phone or email to the other Consultants Consultants and Grantee’s staff Team Leader Facilitates Pre-Site Visit Responsible for working with Conference Call PO, Grantee, and Consultants to finalize the Site Visit Agenda Pre-Site Visit Activities Role of Team Leader Pre-Site Visit Conference Call • Facilitates the Pre-Site Visit Conference Call (reiterate purpose, introduce Team, and ensure that a review of the site visit process is presented to the grantee). • Ensures the grantee will arrange for a confidential Consumer Panel interview (preferably during a lunch). • Ensures the grantee’s necessary staff and subcontractors (if applicable) are available for interviews during the site visit. Pre-Site Visit Activities Role of Team Members Responsible for making personal travel arrangements with contractor. Reads the Pre-Site Visit Informational Packet. Responsible for participating on the Pre-Site Visit Conference Call. Makes him/herself directly available by phone or email to the other Consultants and to the grantee’s staff. On-Site Activities Role of Project Officer • Opens the entrance conference by clarifying the purpose for the site visit; roles of the Team; and introduces the Team. • Provides information on questions related to: HRSA/HAB policy; Program Guidance and Expectations; HAB/Division of Grants Management Operations (DGMO) approved budgets; and HRSA/HAB updates. • Available to Consultants as they obtain information. On-Site Activities Role of Project Officer (cont) • Holds “check-in” meetings with Team Leader and Consultants throughout the visit. • Provides clarification on questions that arise. • Actively participates in Pre-Exit and Exit Conferences (provides closing remarks and “next steps”). On-Site Activities Role of Team Leader Serves as “lead reviewer,” getting directions to sites and facilities, etc. Serves as a mediator in discussions or when disagreements arise. The “lead reviewer” is responsible for ensuring that the Site Visit Team completes a review that meets the spoken and written instructions of the Project Officer. Facilitates meetings and handles on-site team logistics (e.g. rental car, when applicable). On-Site Activities Role of Team Leader (cont) “Checks in” with the Project Officer and Team Members on a regular basis to ensure that the site visit is progressing as expected or to make needed adjustments to the agenda. Usually serves as the facilitator of the Consumer Panel meeting. Ensures the preparedness of the entire Team for the Pre-Exit and/or Exit Conference. Provides feedback as necessary to Team Members. On-Site Activities Role of Team Members Participates in the following meetings: Entrance Conference, Consumer Panel, Pre-Exit and/or Exit Conference. Efficiently conducts review of materials and staff interviews. “Checks-in” with the Project Officer and Team Leader on a regular basis. Is fully prepared to make their remarks at the PreExit and/or Exit Conference. Post-Site Visit Activities Role of Team Members • Submit written report to Team Leader within one week of completion of site visit. • Provide any clarification or edits as requested. Post-Site Visit Activities Role of Team Leader • Compiles and submits final Site Visit Report within two weeks of completion of site visit. • Contacts Team Members for edits requested by Project Officer. Post-Site Visit Activities Role of Project Officer • Reviews and provides feedback to Team Leader on Site Visit Report. • Assures the completion and release of the Site Visit Report to the grantee within four weeks of the conclusion of the site visit. • Monitors completion of grantee’s Corrective Action Plan and provides technical assistance when necessary. Contractor and Project Officers Roles The Contractor is responsible for issuing all reimbursement for consultants’ out of pocket expenses and honorariums for site visits. Honorariums are issued by the contractor upon final approval of the Site Visit Report by the Project Officer. All communication concerning consultant reimbursement should be sent to the Contractor. Team Member Professional Standards Confidentiality CONFIDENTIALITY: As a Consultant, you must fully understand the confidential nature of the site visit discussions related thereto and agree: (1) to return all copies of review-related materials; (2) to erase all electronic review-related materials; (3) not to discuss these materials or the site visit review proceedings with any individual except the staff of Health Resources and Services Administration (HRSA) and Grants Management Officials; and (4) to refer all inquiries made concerning any aspect of the review proceedings to the HRSA Project Officer in charge of the review. Team Member Professional Standards • Maintain utmost degree of professionalism at all times. • Strike a balance in decorum. Avoid opposite extremes - being condescending or being overly-friendly. • Avoid expressing personal opinions on the policies and procedures of DHHS, HRSA, or HAB. Avoid personal biases (“That’s not how WE do it at OUR clinic.”) Team Member Professional Standards • Refrain from conducting personal business on Federal time. • Avoid even the slightest PERCEPTION of a “Conflict of Interest.” • Never market personal consulting services or products (e.g. books you have authored, etc.). Team Member Professional Standards • Refrain from accepting significant gifts, meals, drinks, etc. from grantees. Items of nominal value (e.g. t-shirt, pens, button, coffee mug, etc.) are permissible. • If the Consumer Panel is during lunch (optimal), the Team Members are expected to contribute their portion of the cost of the meal. Team Member Professional Standards • Be respectful of the time and availability of the grantee’s staff, consumers, Board Members, and subcontractors. • Be thorough in your review with as little disruption of the grantee’s workplace as possible. • Be respectful of your fellow Team Members’ time and efforts. • Be fully prepared for Pre-Exit and Exit Conferences. • Be respectful of the grantee’s organizational culture! • Frame your closing remarks to be sensitive to the culture of the grantee. Site Visit Assessment Tool Site Visit Assessment Tool What’s New? Name – Site Visit Assessment Tool Core Site Visit Requirements At A Glance Introduction page Mission, Vision, and respective websites Reason – to familiarize the Consultant with our services and brand Site Visit Assessment Tool What’s Old? What’s New? Site Visit Categories •4 – Administrative •5 – Fiscal •8 – Clinical Site Visit Requirements We have identified a separate authority and resource for each requirement for a total of: •4 – Administrative •4 – Fiscal •4 – Clinical MIS – included as a separate category at the end of each module MIS – we have integrated MIS into all requirements Improvement options All improvement options were removed. Reason – to place focus on legislative authorities and essential elements versus citing grantees for trivial issues. This approach will lead to a more streamlined report and concise corrective action plan. Site Visit Assessment Tool What’s Old? Fiscal – reference tools What’s New? A separate document that will accompany the Site Visit Assessment Tool with reference material. Resources added below each requirement. Reason – to assist Consultants in identifying materials for review No sub-categories Sub-categories added under each requirement Reason – for relative ease in reviewing the tool by grouping similar subject matter Findings – potential for numerous findings Consultants will identify findings based on 12 requirements. Each finding will not be addressed individually within the report. Reason – provide a more tailored approach to the exit conference, report, and corrective action plan. Project Officer can provide more targeted TA based on respective requirement. Core Site Visit Requirements At A Glance Section I: Administrative 1 2 3 4 Sections 2601-2692 of title XXVI of the PHS Act; 42 USC §300ff-11, §300ff-111; 45 CFR 74; 45 CFR 92; 2 CFR 215; HHS Grants Policy Statement (2007); HAB Policy Notice 11-02 Administrative Structure and Management Grantee maintains a fully staffed management and clinical team as appropriate for the size and needs of the program. The organization has established appropriate oversight and authority over all aspects of the program. Data Reporting Grantee has systems which accurately collect and organize data for program reporting and which support management decision making. Section 2664 (a), Section 2671 (c), and Section 2691 (b) of title XXVI of the PHS Act; 42 USC §300ff-64, §300ff-71, and §300ff-101; FOA Grantee makes efforts to establish and maintain collaborative relationships with medical and support providers. Section 2651 (e) and Section 2671 (c) of title XXVI of the PHS Act; 42 USC §300ff-51 and §300ff-71; HAB Policy Notice 12-01 System Coordination Accessibility, Confidentiality, and Cultural Competency Grantee has policies and procedures that address HIV/AIDS related confidentiality and program processes that include limiting access to passwords, electronic files, medical records, faxes and release of client information. Grantee adheres to accessibility and National Standards on Culturally and Linguistically Appropriate Services (CLAS). Section 2652 (a) (2) and Section 2661 (a) of title XXVI of the PHS Act; PL104-191 HIPPAA; CLAS Standards Core Site Visit Requirements At A Glance continued Section II: Clinical 5 6 7 8 HIV Counseling, Testing, Referral, and Patient Enrollment Grantee maintains formal linkages to HIV Counseling, Testing, Referral, and partner counseling either on site or from other sources that are available and accessible to the targeted population(s). Section 2651 (e) (1) (A) and (B), Section 2661 (a) and (b), and Section 2662 (a) and (b) of title XXVI of the PHS Act HIV Medical Care Grantee provides a comprehensive continuum of outpatient HIV primary care services within a targeted area that attempts to link persons with HIV disease as early in the course of infection as possible and retain them in medical care. Program must reflect a medical model of care that remains abreast of clinical advances in which providers can assess, treat, and refer patients. Section 2651 (c) (3), (e) (D) and (E) of title XXVI of the PHS Act Other Services to Support HIV Clinical Outcomes Grantee ensures access, either directly or via referral, to oral health care, adherence counseling, outpatient mental health care and substance abuse treatment, nutritional services, and specialty medical care. Formal arrangements such as contracts or memoranda of agreements are established with appropriate providers as applicable. Section 2651 (c) (3), (d) of title XXVI of the PHS Act. Clinical Quality Management Program Grantee has established a clinical quality management (CQM) program that assesses the extent to which HIV health services are consistent with performance standards as defined by HHS benchmarks and quality indicators. Grantee’s CQM program includes an evaluation component that measures performance and continuously plans, implements, evaluates, and incorporates strategies to improve delivery of care. Section 2664 (a) (3), (g) (5) and Section 2671 (f) (2) of title XXVI of the PHS Act Core Site Visit Requirements At A Glance continued Section III: Fiscal Ryan White Budget and Use of Funds Grant Funds are budgeted and expended for approved activities in alignment with applicable Federal legislation and program requirements. Section 2664 (g), Section 2651 and Section 2671 of title XXVI of the PHS Act; 2 CFR Parts 215, 220, 225, and 230; 45 CFR Part 92; and OMB Circular A-133 10 Fiscal Management and Oversight Grantee maintains accounting and internal control systems appropriate to the size and complexity of the organization reflecting Generally Accepted Accounting Principles (GAAP) and separates functions appropriate to organizational size to safeguard assets, maintain financial stability, and account for the appropriate expenditure of Ryan White funds. Section 2664 (g) of title XXVI of the PHS Act; 2 CFR Parts 215, 220, 225, and 230; 45 CFR Part 92; and OMB Circular A-133 11 Third Party Reimbursement: Billing, Collections, and Program Income Reporting Grantee has systems in place to identify and maximize collections and reimbursement for its costs in providing health services, including written billing, credit and collection policies and procedures, and how such revenue is invested in the Ryan White funded program. Section 2652 (b) and Section 2664 of title XXVI of the PHS Act; 2 CFR 215 and 45 CFR 92 12 Sliding Fee Discounts and Annual Cap on Charges Grantee has a system in place to determine eligibility for patient discounts and maintains legislative Sliding Fee Scale and Annual Cap on Charges to ensure no one is denied services based on an inability to pay. Section 2652 (b) and Section 2664 of title XXVI of the PHS Act; 2 CFR 215 and 45 CFR 92 9 Snapshot of a Requirement Requirement 3: System Coordination Authority: Section 2651 (e) and Section 2671 (c) of title XXVI of the Public Health Service Act; 42 USC §300ff-51 and §300ff-71; HAB Policy Notice 12-01 Resources: 1) Contracts/MOAs; 2) SOPS; and 3) EHR/EMR Management Does the program have collaborative relationships with other health care providers, other community centers, other RW providers, as well as local, state, and private organizations providing similar or complimentary services in the community? Yes/Met No Partially Met N/A Not Met Site Visit Report Title XXVI of the PHS Act as amended by the Ryan White HIV/AIDS Treatment Extension Act of 2009 (Ryan White Program) Site Visit Report Grantee Information: Grantee Name: Grant Number: Type of Visit: Purpose of Visit: Comprehensive ____ Diagnostic ____ Technical Assistance____ The purpose of this site visit was to assess grantee’s compliance with the legislative and programmatic requirements of the Ryan White Part [C Early Intervention Services (EIS)] Program. The site visit team reviewed the clinical, fiscal, Management Information Systems (MIS), administrative and support services of the HIV program operations. [State Reason that prompted this particular site visit] Date(s) of Visit: Project Officer: Consultant(s): Overview of Grantee Organization: Include brief summary of organizations’ model of care, hours of operations, services provided, client demographics, third party payors, summary of chart audit review, and consumer panel. Defining Use of Met / Partially Met / Not Met Met •All elements of a Requirement are met. •No findings or recommendations should be included within the Site Visit Report under the specific Requirement. Partially Met •Not all elements of the Requirement are met. •Include findings and recommendations that were not met within the Site Visit Report under the specific Requirement. Not Met •All elements of a Requirement are not met. •Include findings and recommendations within the Site Visit Report under the specific Requirement and reflect a “must” in this case. Site Visit Report Sample of a Requirement Section I. Administrative 3. System Coordination: Grantee makes efforts to establish and maintain collaborative relationships with medical and support providers. Authority: Section 2651 (e), and Section 2671 (c) of title XXVI of the Public Health Service (PHS) Act; 42 USC §300ff-51 and §300ff-71; HAB Policy Notice 12-01 Met/ Partially Met/Not Met: Finding(s): Recommendations: Tips for Writing a Concise and Comprehensive Site Visit Report • Limit “overview” to one page (Refer to Site Visit Report for an example) • Limit total pages to 10. • If a Requirement is not met or partially met provide a short description of finding(s) and recommendation(s). • Only include findings related to the Requirements. Remember to: Communicate with the Project Officer Follow the site visit template Tailor the report to the findings discussed in the Exit Conference Produce a clear and concise report Meet the Site Visit Report deadline of two weeks following conclusion of the site visit. Questions should be emailed to David Pitman at DPitman@hrsa.gov FY 2013 Administrative Requirements Part C HIV Early Intervention Services (EIS) Part D Grants for Coordinated HIV Services and Access to Research for Women, Infants, Children, and Youth (WICY) Part F – Dental Presented by: Department of Health and Human Services Health Resources and Services Administration HIV/AIDS Bureau Division of Community HIV/AIDS Programs Purpose The following webinar is offered in support of the Health Resources and Services Administration’s (HRSA), HIV/AIDS Bureau (HAB), Division of Community HIV/AIDS Programs (DCHAP), 2013 Site Visit Assessment Tool. Webinar Goal • To increase HRSA/HAB/DCHAP’s Ryan White Part C, D, and F Consultants’ and Project Officers’ knowledge of how to effectively assess and report on the grantee’s provision of comprehensive, high quality healthcare for people living with HIV/AIDS; compliance with legislative and programmatic requirements; and the National HIV/AIDS Strategy. • To learn to effectively assess compliance and report findings based on administrative practices required by legislation. Webinar Objectives By the end of the webinar, participants will be able to: • • • • Apply knowledge of how to effectively assess compliance and report findings based on administrative practices required by law List the four Requirements of the Administrative Module Determine if an agency has fully met, partially met, or not met components of each requirement. Identify the sources to review to ensure that the grantee meets the stated requirement. Webinar Outline • • • • Administrative Structure and Management Requirement Data Reporting Requirement System Coordination Accessibility, Confidentiality, and Cultural Competency Administrative Module Administrative Module Components • • • • • • Corporate organization and structure Governance Strategic and short term planning Personnel policies and procedures Clinical personnel issues Data collection • Capacity • Licenses and certification • Risk management and liability protection • Facility networking • Collaboration • Linkages • Outreach and education services • Consumer involvement Administrative Module The Administrative Module addresses the following four requirements: • • • • Administrative Structure and Management Data Reporting System Coordination Accessibility, Confidentiality and Cultural Competency Core Site Visit Requirements At A Glance Section I: Administrative 1 2 3 4 Sections 2601-2692 of title XXVI of the PHS Act; 42 USC §300ff-11, §300ff-111; 45 CFR 74; 45 CFR 92; 2 CFR 215; HHS Grants Policy Statement (2007); HAB Policy Notice 11-02 Administrative Structure and Management Grantee maintains a fully staffed management and clinical team as appropriate for the size and needs of the program. The organization has established appropriate oversight and authority over all aspects of the program. Data Reporting Grantee has systems which accurately collect and organize data for program reporting and which support management decision making. Section 2664 (a), Section 2671 (c), and Section 2691 (b) of title XXVI of the PHS Act; 42 USC §300ff-64, §300ff-71, and §300ff-101; FOA Grantee makes efforts to establish and maintain collaborative relationships with medical and support providers. Section 2651 (e) and Section 2671 (c) of title XXVI of the PHS Act; 42 USC §300ff-51 and §300ff-71; HAB Policy Notice 12-01 System Coordination Accessibility, Confidentiality, and Cultural Competency Grantee has policies and procedures that address HIV/AIDS related confidentiality and program processes that include limiting access to passwords, electronic files, medical records, faxes and release of client information. Grantee adheres to accessibility and National Standards on Culturally and Linguistically Appropriate Services (CLAS). Section 2652 (a) (2) and Section 2661 (a) of title XXVI of the PHS Act; PL104-191 HIPPAA; CLAS Standards Requirement 1 - Administrative Structure and Management Grantee maintains a fully staffed management and clinical team as appropriate for the size and needs of the program. The organization has established appropriate oversight and authority over all aspects of the program. Requirement 1 - Administrative Structure and Management Authority: • Sections 2601-2692 of title XXVI of the PHS Act • 42 USC §300ff-11 and §300ff-111 • • • • 45 CFR 74 and 92 2 CFR 215 HHS Grants Policy Statement (2007) HAB Policy Notice 1102 Source documents: • Organizational Chart • SOPs • Contracts/MOAs for core providers • Job Descriptions • Meeting Minutes • Sub-recipients agreements, if applicable Requirement 1 - Administrative Structure and Management For each question in this section: Determine if the agency has fully met, partially met, or not met components of each requirement. For example, when reviewing the personnel files for evidence of orientation and training, policy, procedures and other requirements, ask questions to prompt discussion with staff and will aid the review of this requirement. Requirement 1 - Administrative Structure and Management Example Is Senior Management aware of the local health care environment and its impact on provision of services (e.g. state budget cuts, ADAP, ACA, managed care, etc.). If so, is it reflected in the strategic planning process and the latest agency Strategic Plan? Examples of Administrative Structure and Management Met, Partially Met, Unmet Standards Met • • • Grantee Senior Management has approved most recent personnel manual. Personnel files located in a secure location Staff position descriptions are documented, current, and readily available . Partially Met • • Inconsistent after hours policy. Job descriptions are available but not current. Unmet • • • • HIPAA patient confidentiality violations There are no policies and procedures for after hours or emergency coverage for medical or dental services Job descriptions do not accurately reflect the position requirements of the work in the Part C/D funded program Personnel files are incomplete. Requirement 2 - Data Reporting Grantee has systems which accurately collect and organize data for program reporting and support management decision making. Requirement 2 - Data Reporting Authority: • Section 2264 (a), Section 2671 (c), and Section 2691 (b) of title XXVI of the PHS Act • 42 USC §300ff64, §300ff-71, and §300ff-101 • FOA Reporting Requirements Source documents: • RSR Report and RSR Completeness Report • SOPs • EMR/ EHR • CAREWare Requirement 2 - Data Reporting Evaluate the capacity and system of data collection Are there policies in place for data reporting? Requirement 2 - Data Reporting Example Does the grantee reconcile the practice management system to the Ryan White Services Report? Examples of Data Reporting Met, Partially Met, Unmet Standards Met • • • Grantee has IT policies • and procedures around confidentiality and access, and the accuracy of data found in required reports. MIS in place and interfacing with CAREWare, EHRs/EMRs, the data collection process, and cross checks between a MIS and submitted reports. Grantee demonstrates that the practice management system data matches the RSR report. Partially Met Policy and procedure manuals are in place but does not interface with CAREWare, EHRs/EMRs, the data collection process, or cross checks between MIS and submitted reports. Unmet • • • Sometimes only the IT department knows how to work the system Staff not familiar with the IT capabilities Grantee does not have the infrastructure to support IT Requirement 3 - System Coordination Grantee makes efforts to establish and maintain collaborative relationships with medical and support providers. Requirement 3 - System Coordination Authority: • Section 2651 (e) and Section 2671 (c) of title XXVI of the PHS Act • 42 USC §300ff-51 and §300ff-71 • HAB Policy Notice 12-01 Source documents: • Contracts and/ or MOAs • Standard Operating Procedures • Electronic Health/ Medical Records Requirement 3 - System Coordination • Ensure that grantees have collaborative relationships • Evidence of MOA coordination and linkages with CDC Funded HIV Testing and outreach services, local Health Departments, ASOs, and Faith Based Organizations • Participation in the Statewide Coordinated Statement of Need Requirement 3 - System Coordination For example, System Coordination should determine if the organization has an appropriate system which ensures care coordination and collaborative relationships with medical and support providers. Examples of System Coordination Met, Partially Met, Unmet Standards Met • • • Has a current MOA that clearly defines the extent of the relationship with the organization Detailed Policy and Procedures highlighting how to refer patients to care Active Participation with Title V of the Social Security Act and Maternal and Child Health Services agencies. Partially Met • Has Policy and Procedures highlighting how to refer patients to care and participates with Title V of the Social Security Act and Maternal and Child Health Services agencies but does not have a current MOA. Unmet • Dated MOA, no established collaboration with other RW organizations, AETC, FQHC, CDC Funded HIV Testing and Outreach Services. No Mental and Clinical services. • No policies and procedures regarding referral of Care • Does not participate with Title V of the Social Security Act and Maternal and Child Health Service agencies. Requirement 4 - Accessibility, Confidentiality, and Cultural Competency Authority: • Section 2652 (a) (2) and Section 2661 (a) of title XXVI of the PHS Act • PL104-191 HIPPAA • CLAS Standards Source documents : • Policies and Procedures; • Contracts/MOAs; • Licenses • Certifications • Tour of Facility Requirement 4 - Accessibility, Confidentiality, and Cultural Competency Reviewing Facility/Risk Management, Cultural Competency and Confidentiality. Requirement 4 - Accessibility, Confidentiality, and Cultural Competency Does the grantee have a clear confidentiality statement signed in personnel file? In this instance, consultants are encouraged to review 30% of the personnel files. Examples of Accessibility, Confidentiality, and Cultural Competency Met, Partially Met, Unmet Standards Met • • • • • • Grantee has documented their staff attendance at Cultural Competency Trainings Policies are in line with American with Disabilities Act and site has handicap accessibility Risk Management policies and procedures are documented Clients are receiving culturally competent care HIPPA rules and regulations are being followed Employees sign a confidentiality statement that is clearly in personnel files. Partially Met • No current documentation of Cultural Competency Trainings. Unmet •Inadequate policy regarding Translation Services for patients. •Inadequate documentation of cultural competency trainings for staff. •Policies are not in line with American with Disabilities Act and site does not have handicap accessibility. Questions should be emailed to David Pitman at DPitman@hrsa.gov Next Steps Please note that successful completion of this webinar is one qualifying component for selection as a HRSA/DCHAP Site Visit Consultant. 1) Within two business days, an email will be sent to all participants that will include a Consultant Questionnaire and a Post Test Exam. 2) Please return a signed scanned copy of the completed Post Test Exam and Questionnaire along with a current resume/CV to David Pitman at DPitman@hrsa.gov within two business days of receipt of the email. Contact Information Karen Gooden, Co-Chair DCHAP Site Visit Workgroup kgooden@hrsa.gov Sandra Lloyd, Co-Chair DCHAP Site Visit Workgroup slloyd@hrsa.gov John Fanning, DCHAP Senior Policy Advisor jfanning@hrsa.gov HHS/HRSA/HAB/DCHAP 301-443-0493