1. © Wipfli LLP 1 Date or subtitle © Wipfli LLP Jeff Bramschreiber, CPA, Partner Wipfli Health Care Practice Iowa Association of Rural Health Clinics RHC Survey and Certification October 1, 2014 10:45 a.m. - 11:45 a.m.

2. © Wipfli LLP I.RHC Survey and Certification Overview II.Discussion of Recent Surveys Discussion Topics 2

3. © Wipfli LLP 3 RHC Survey & Certification Overview © Wipfli LLP

4. 4 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.

5. © Wipfli LLP 5 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

6. © Wipfli LLP 6 Table of Contents Chapter 1Overview of the RHC Program Chapter 2Getting Started - Does Your Site Qualify? Chapter 3Feasibility Analysis - Is The RHC Program For You? Chapter 4How to File the RHC Application Chapter 5Preparing for the RHC Certification Inspection Chapter 6Completing the Cost Report Chapter 7RHC Coding and Billing Issues Appendix AState Survey and Certification Agencies Appendix BState Offices of Rural Health Appendix CCriteria for Designation as a HPSA or MUA Appendix DSample Policy and Procedures Manual Appendix EOther Resources Starting a RHC – A How-To Manual RHC Survey Resources

7. © Wipfli LLP 7 CMS-30 (Rural Health Clinic Survey Report) RHC Survey Resources

8. © Wipfli LLP 8 State Operations Manual – Appendix G RHC Survey Resources

9. © Wipfli LLP 9 CodeSectionRegulation 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. Common RHC Survey Deficiencies RHC Survey Resources

10. © Wipfli LLP 10 CodeSectionRegulation J22 491.6(b)(1) The clinic has a preventive maintenance program to ensure that all essential mechanical, electrical and patient- care 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. Common RHC Survey Deficiencies (cont.) RHC Survey Resources

11. © Wipfli LLP 11 Common RHC Survey Deficiencies (cont.) CodeSectionRegulation 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. RHC Survey Resources

12. © Wipfli LLP 12 Common RHC Survey Deficiencies (cont.) CodeSectionRegulation 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. RHC Survey Resources

13. © Wipfli LLP 13 Common RHC Survey Deficiencies (cont.) CodeSectionRegulation 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. RHC Survey Resources

14. © Wipfli LLP 14 Common RHC Survey Deficiencies (cont.) RHC Survey Resources

15. © Wipfli LLP  Appendix G Interpretive Guidelines – Rural Health Clinics State Operations Manual (HCFA-Pub. 7)  42 CFR §491 (RHC Regulations)  Starting a RHC – A How To Manual www.bphc.hrsa.dhhs.gov www.narhc.org www.nrharural.org RHC Sources of Information  AAAASF/RHC - RHC Medicare Accreditation www.rhcaccreditation.org

16. © Wipfli LLP 16 Discussion of Recent Surveys © Wipfli LLP

17. 17 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?

18. © Wipfli LLP Questions ? 18

19. © Wipfli LLP 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 19

20. © Wipfli LLP www.wipfli.com 20 www.wipfli.com