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Maine Primary Care AssociationBoard Governance Training
MPCA Annual ConferenceBar Harbor Club
October 22, 2014
Your Presenters Today:
Darcy Shargo, COO
Jeb Murphy, Director of Communication and Data Coordination
Dan Washburn, CFO
Becky Colella, Risk Management/Emergency Preparedness
Coordinator
We’re Here to Help Health Centers!
The Maine Primary Care Association works to assist health centers in multiple ways:• Advocacy• Informational Resource• Training and Technical
Assistance
Our Training and Technical Assistance isn’t just targeted at employees of health centers; we can also engage Community Health Center boards, mainly through two offerings:
• Tailored Board Governance Trainings (Tell Us What You Need Covered)
• Annual Compliance Trainings (Covering board and staff expectations)
Our Programs
• Communication and Data Coordination• Outreach and Enrollment (with focus on the Affordable Care Act)• Behavioral and Dental Health Integration• Advocacy• Health Information Technologies (HIT)
• Quarterly Regional Roundtables• Heath Center Controlled Network (HCCN)
• Quality Improvement• Patient Navigation Network• Emergency Preparedness/Risk Management (You’ll hear about
today!)
Interested in learning more about the work being done or looking for a place to sit in and learn about the “boots on the ground” work? Check out our Events Calendar on the MPCA Website
(www.mepca.org)
For the most up to date information about MPCA and Our Health Centers
Like us on Facebook at Facebook.com/MainePCA
Follow us on Twitter @MainePCA
A Brief History…..• Community Health Center (CHC) model emerged in
the 1960s to target roots of poverty with local focus, incl. local governance and accountability
• CHC funding called “Section 330 funding” and refers to $$ for health centers to serve community, homeless, public housing, or migrant populations
• Program oversight from the Health Services and Resources Administration (HRSA)
Community Governance is Hallmark of CHCs• No other health care provider has the level of
community governance or guidance that CHCs do
• Creates another layer of responsibility to align with program requirements
• Need guidance and governance to help CHC do what it supposed to do• Need linkage to the community and a way to ensure that the CHC is meeting the local needs in the towns it serves• Community members are an essential part of promoting the mission of the CHC and the great work that it does• Your CHC is a non-profit business and needs a governing board to hold it accountable-state and federal laws require that for 501 © 3 status (duty of care, loyalty and obedience)
Why Have a Board?
What else is unique about CHCs?
• 100% of Maine CHCs are currently meeting or exceeding Healthy People 2020 Goal metrics
• Certified Application Counselors at Maine CHCs helped Maine become the #1 State for Enrollments per capita (with a Federally Facilitated Marketplace) in the nation
• Currently 95% of Maine’s CHCs are PCMH Recognized, while the national average is 54%
What are core needs for good CHC governance?
• Define and preserve mission• Make policies (aligning with federal
program priorities and community needs)• Safeguard the assets of the CHC• Select, Evaluate, and Support CEO• Monitor and Evaluate the BOD itself• Plan for the future
• Know the CHC mission, strengths, and weaknesses
• Participate at BOD meetings• Support CEO and staff and understand they
are operating with limited resources• Avoid conflict of interest• Understand CHC financials and help the BOD
plan accordingly
CHC Board Best Practices
• Don’t lose your sense of humor-this work can be very hard!
• Don’t forget the CHC program requirements-many of which demand Board attention and review on a regular basis
CHC Board-Things to Watch Out For
CHC Program Requirements• Part of overall compliance strategy (think
“duty of care.”)• 19 requirements that make up the CHC
program-covering areas such as “key management staff” to “conflict of interest” for BOD members
• Represent areas of risk to CHC funding because of increased scrutiny on CHC program
• Sets standards that represent HRSA/BPHC position on issues ranging from internal operations to third party arrangements
• Interprets, explains, expands and updates rules that may be too broad, unclear, vague or out of date
• 19 Health Center Program Requirements:Legal standards mandated by health center statute/regulationsGrouped into four sections that generally reflect the core components of the health center program: need, services, management & finance, and governance
Program Information Notices (PINs) & Program Assistance Letters (PALs)
High Risk Areas-Program Requirements
What’s at stake?
Special award conditions“High-risk” designation (triggered by 5 conditions):- Cost disallowances- Draw-down restrictions- Suspension/termination of funding- Re-Competition of your grant.- Any other remedies legally available and appropriate
What are the Program Requirements Causing the Most Challenge for CHCs?
Scope of ProjectRequired and Add’l Services
Board AuthorityBoard CompositionSliding Fee Scale
Collaboration/Affiliations
MUST …approve general health center policies…
For Example: • Sliding Fee Discount Program• Patient Centered• Improves Access• No patient denied health care due to
an inability to pay
Must…• Periodically review evaluations• Assess their effectiveness• Assess their appropriateness• Organizational training
Risk Management and Emergency Preparedness:
A deeper dive into an emerging topic for
Community Health Center Boards
MPCA EP Offerings
Health Center Emergency
Preparedness Task Force
Shared Learning &
Program Development
Webinars
Weekly Emergency
Preparedness Updates
1:1 Training & Technical
Assistance
Health Center Responsibilities for Emergency Preparedness
• Emergency Management Planning
• Linkages & Collaborations
• Communications & Information Sharing
• Maintaining Financial & Operational Stability
HRSA PIN 2007-15
HRSA PIN 2007-15: Maintaining Financial & Operational Stability
• Effort within an organization to ensure the continuity of essential functions
Continuity of Operations
Maintaining Financial & Operational Stability
Business Interrupti
on
Managing and
insuring against…
Business
Continuity
Equipment
Failure/ Loss/
Damage
Health Center Responsibilities for Risk Management
• Communication—reporting and tracking test results, physician-to-physician communication, and patient education
• Special patient concerns—newborns, minors, elderly, and pregnant patients
• Obstetrical risk management
HRSA
Health Center Responsibilities for Risk Management
• Corporate Compliance– Jacqueline Leifer, Esq. highlighted this as a Board
responsibility
“Section 330 implementing regulations require a health center’s Board of Directors to ensure that the health center is operated
in compliance with applicable Federal, State & Local laws & regulations”
FTLF highly recommends that health centers have an
integrated compliance program
Team Based Approach
Health Center Board’s Role in Compliance
•Review & update compliance program policies
•Review & evaluate compliance program work plan
•Monitor investigations via reports from compliance officer
•Evaluate overall effectiveness
Action Steps
For CHCs who have not yet established a compliance program:
• Pass resolution to establish the program & approve policies• Consider establishing a committee of the Board• Request regular reports on Compliance Program development
For CHCs with an established Compliance Program
• Request annual compliance program evaluation• Ensure sufficient funds are made available for the program• Modify and/or approve policies• Request regular reports from Compliance officer(s)
MPCA’s Risk Management Program
4 Buckets
Clinical
Operational
Financial
Legal & Regulatory
Corporate Compliance touches on all 4 buckets
Next Steps
Determine health center risk
management needs & priorities
• Direct feedback• Survey Data