Comprehensive Analysis Report Sample - National Association 综合分析报告的样本国家协会

1、 Copyright 2021 National Association of Community Health Centers. All rights reserved.Americas Voice for Community Health CareThe National Association of Community Health Centers (NACHC) represents Community and Migrant Health Centers, as well as Health Care for the Homeless and Public Housing Prima

2、ry Care Programs and other community-based health centers. Founded in 1971, NACHC is a nonprofit advocacy organization providing education, training and technical assistance to health centers in support of their mission to provide quality health care to medically underserved populations. Copyright 2

3、021 National Association of Community Health Centers. All rights reserved.The NACHC MissionTo promote the provision of high quality, comprehensive and affordable health care that is coordinated, culturally and linguistically competent, and community directed for all medically underserved populations

4、. Copyright 2021 National Association of Community Health Centers. All rights reserved.Integrating Behavioral Health into Primary Care SettingsMichael R. Lardiere, LCSWDirector HIT; Sr. Advisor Behavioral HealthNational Association of Community Health CentersSeptember 14, 2021 Copyright 2021 Nationa

5、l Association of Community Health Centers. All rights reserved. Copyright 2021 National Association of Community Health Centers. All rights reserved.Overview of Current Behavioral Health Delivery in FQHCsIdentification of the “Core Components of Integrated CareReview of legal considerations when int

6、egrating care Copyright 2021 National Association of Community Health Centers. All rights reserved.70% of Health Centers Currently Provide Behavioral Health ServicesAll Health Centers are required to have a behavioral health intervention identified in their annual planBehavioral Health - Rural vs Ur

7、banBehavioral Health - Rural vs UrbanBehavioral Health Visits by Type of Provider% Behavioral Health Staffing by DisciplineTotal Behavioral Health Staffing by Discipline Copyright 2021 National Association of Community Health Centers. All rights reserved.But is the Treatment health centers provide I

8、ntegrated Treatment?What do we mean by Integrated Treatment?What are the Core Components?Co-LocationCommunicationAndCollaborationShared Problem ListsShared Treatment PlansShared Medication Lists AndLab ResultsJoint Decision MakingIntegrated Primary and Behavioral HealthcareSpecialty Behavioral Healt

9、hcareorPrimary Care SettingShare ExpertiseShare StaffShare Open Access Scheduling ExperienceCommunication & Collaboration as Patient Moves Between SystemsBehavioral Health Integration in Primary Care: Making it Real (Morehouse University, Carter Center, HRSA, SAMHSA Oct. 2021)Core Components of Succ

10、essful Integrated Models M. Lardiere 12/2021 Copyright 2021 National Association of Community Health Centers. All rights reserved. Copyright 2021 National Association of Community Health Centers. All rights reserved.Statutory requirementUnder Section 330 of the Public Health Service Act (42 USC 254b

11、), all FQHCs must provide “Required primary health services, which are defined to include “referrals to providers of other health-related services (including substance abuse and mental health services) 42 USC 254b(a)(1) & (b)(1)(A)(ii)NOTE: Programs receiving targeted Health Care for the Homeless fu

12、nds must provide additional substance abuse services (detoxification, risk reduction, outpatient treatment, residential treatment, rehabilitation in non-hospital settings) - 42 USC 254b(h) Why Provide BH Services? Copyright 2021 National Association of Community Health Centers. All rights reserved.

13、Why Provide BH Services?HRSA priority (as evidenced by service expansion funding opportunities)Important components Enhances ability to provide comprehensive primary careIncreases access to essential services which assist in ensuring the overall health and well-being of community and patients served

14、 Copyright 2021 National Association of Community Health Centers. All rights reserved.Includes Mental Health ServicesSuch as pharmacological management, assessment, psychiatric diagnostic interview, individual and group counseling, crisis interventionIncludes Alcohol and Drug ServicesSuch as ambulat

15、ory detoxification, assessment, case management, crisis intervention, individual and group counseling, lab urinalysis, medical/somatic, methadone administration, Buprenorphine administration, SBIRT Copyright 2021 National Association of Community Health Centers. All rights reserved. HRSA GuidanceBH

16、program should include the following components (cont.)Application of exemplary practices and lessons learnedEffective risk management practicesIncorporation of program activities into the FQHCs quality planServices can be provided on-site or off-site through an established contractual arrangementHR

17、SA strongly encourages using an integrated primary MH/SA care model in developing the service delivery planDelivery of brief patient-centered MH/SA consultationsCo-management of patients by MH/SA providers (who are “members of primary care team) and medical providers Copyright 2021 National Associat

18、ion of Community Health Centers. All rights reserved.FQHCNational SystemSafety Net ProviderNeed-Based ServicesPrevention-OrientedLifespan CareCMHCState-DefinedMedicaid ProviderEligibility-Based ServicesRehab-OrientedEpisodic CareTraditional Key Differences Between FQHCs and BH Providers Copyright 20

19、21 National Association of Community Health Centers. All rights reserved.FQHC takes sole responsibility for providing BH ServicesFQHC Purchases Services from BH Specialty ProviderReferral RelationshipBH Specialty Provider locates their services in same location as FQHCBH Provider located off site at

20、 another locationMethods of Integration Copyright 2021 National Association of Community Health Centers. All rights reserved.FQHC takes sole responsibility for providing BH ServicesEasiest to ImplementNo Special Legal considerationsRequires Clinical ExpertiseSupervisionLinkages with BH specialty Pro

21、viders are still required for patients that require services beyond FQHC clinical capacity/expertise Copyright 2021 National Association of Community Health Centers. All rights reserved.Purchase of Services/CapacityFQHC purchases BH services and/or personnel from BH Provider - services provided on b

22、ehalf of FQHCFQHC maintains control over and is legally and financially responsible for contracted servicesPatients are considered FQHC patientsBH Provider provides assurances to meet FQHCsProfessional standardsClinical and other pertinent policies, procedures and protocolsQuality assurance standard

23、sData collection standardsMedical records preparationFinancial and programmatic reportingStandards of careProductivity standards (as applicable) Copyright 2021 National Association of Community Health Centers. All rights reserved.Purchase of Services/CapacityOther BH Provider assurances Act consiste

24、nt with Section 330 rulesEligible to participate in Federal health care programs (not suspended or excluded)FQHC can evaluate BH Provider and, if necessary Suspend services or assigned personnel Terminate assigned personnel or contract in its entiretyFQHC provides payment to BH provider based on arm

25、s length negotiated, fair market value rate (reasonable, in accordance with federal cost principles of OMB Circ A-122)Note: If the health center is paying less than fair market value, the agreement should meet the requirements of the health center safe harbor (42 C.F.R. 1001.952(w) FQHC bills and co

26、llects from patients and third party payors Copyright 2021 National Association of Community Health Centers. All rights reserved.Purchase of Services/CapacityFQHC assumes operations and financial authority over the BH program that is integrated into the FQHCs delivery systemBH providers clinicians m

27、ay be integrated into the FQHC workforce or their time/services may be purchased by the FQHC through a purchase of services/clinical capacity agreement Copyright 2021 National Association of Community Health Centers. All rights reserved.Referral RelationshipsBH Provider agrees to furnish services to

28、 FQHC patients referred by the FQHC, regardless of ability to pay (subject to capacity limitations)BH Provider retains control and liabilityPatients are considered BH Providers patientsFQHC disclaims liability for services provided by BH Provider BH Provider is solely liable for damages related to t

29、he services it provides BH Provider policies/procedures/standards governBH Provider furnishes services consistent with prevailing standards of care (at a minimum) Copyright 2021 National Association of Community Health Centers. All rights reserved.BH Provider keeps separate financial system and bill

30、s and collects from patients and third party payors for services renderedBH Provider agrees to refer patients back to the FQHC for clinically appropriate primary and preventive careReferral Relationships Copyright 2021 National Association of Community Health Centers. All rights reserved.PIN #2021-0

31、1: Requirements for in “in-scope referral arrangementsIf referral provider provides and bills for service, the service itself is not in scopeHowever, the formal referral arrangement and the follow-up care provided by health center will be in-scope if health center:Executes a formal, written agreemen

32、t that describes How referral will be made and managed Process for referring patient back to health center for follow-up careMaintains responsibility for treatment planProvides, pays for and/or bills for appropriate follow-up careInformal referral arrangements CANNOT be used to provide required serv

33、ices or any other “in-scope servicesReferral Relationships Copyright 2021 National Association of Community Health Centers. All rights reserved.Similar to referral relationship, but BH Provider is physically located in and provides services to FQHC patient at FQHC facilityNeed to ensure that the pat

34、ient can distinguish between the FQHC and BH Provider (i.e., separate signage, entrances, registration etc.)Control/liability: same as referral relationshipCircuit riding (contracts on as-needed basis)Co-locationStandards of care: same but FQHC may want right to review and approve themFinancing: sam

35、e as referral relationshipReferral Relationships On-Site Copyright 2021 National Association of Community Health Centers. All rights reserved.42 CFR Part 2 prohibits the transfer of individually identifiable information about a patient that is receiving substance use or alcohol treatment services wi

36、thout valid written specific authorizations, called consentsAlso applies to past patientsMore prohibitive that HIPAA, which generally allows individually identifiable “protected health information to pass for the purposes of treatment, payment, health care operationsAdditional Considerations: Extra Privacy Protections for Substance/Alcohol Diagnosis, Treatment, Referral Information Copyright 2021 National Association of Community Health Centers. All rights reserved.Applies to programs, which are:Individuals or entities (other than general medical facilities), or identified units within gene