The simple answer is no, this would not meet the requirements for compliance outlined in “Chapter 8 – Continuity of Care and Hospital Admitting” (Chapter 8: Continuity of Care and Hospital Admitting) of the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual.  The requirements for this chapter are what would be considered “either/or.”  Either health center providers must maintain admitting privileges at one or more hospitals in the service area, or the hospital must maintain formal written referral arrangements with one or more hospitals in the service area for the purposes of hospital admission of health center patients. 

The question the clinical reviewer must answer in the “Continuity of Care and Hospital Admitting”  section of the HRSA Site Visit Protocol (SVP: Continuity of Care and Hospital Admitting)  is the following:

Does the health center have:

• Documentation of hospital admitting privileges (if select health center providers assume responsibility for admitting and following hospitalized patients: or
• Formal arrangements with non-health center provider(s) or entity(ies) such as a hospital, hospitalist group or obstetrics practice that address health center patient hospital admission. 

Although health center providers may have admitting privileges, if they do not assume responsibility for admitting and following of hospitalized patients, the intent of the standard is not met; therefore, the health center would be required to secure formal, written referral arrangements with one or more hospitals in the service area to ensure continuity of care for hospitalized health center patients across all lifecycles.  It is important to remember that courtesy privileges only authorize a provider to occasionally treat or admit patients into the hospital; therefore, courtesy privileges are not the equivalent of admitting privileges.

Health centers should follow the guidance outlined in “Chapter Eight – Continuity of Care and Hospital Admitting” of the HRSA Health Center Compliance for requirements related to continuity of care and can complete a self-assessment of compliance by answering the questions in the “Continuity of Care and Hospital Admitting” section of the HRSA Site Visit Protocol.