After Hours Process

As outlined by “Chapter 7 – Coverage for Medical Emergencies during and After-Hours” of the Health Resources and Services Administration (HRSA) Health Center Compliance Manual (Compliance Manual Chapter 7), the health center must have clearly defined arrangements in place for promptly responding to patient medical emergencies after the health center’s regularly scheduled hours. One key component of this requirement is for the health center to develop and implement procedures that ensure:

  • After-hours coverage is provided via telephone or face to face by an individual with the qualification and training necessary to exercise professional judgment in assessing a patient’s need for emergency medical care;
  • After-hours coverage includes the option to refer patients either to a Licensed Independent Practitioner (LIP) for consultation, or to locations including urgent care or hospital emergency rooms;
  • After-hours coverage addresses notification of, and ensuring access to, the Limited English Proficiency (LEP) patient population. 

Health centers can meet this requirement a number of different ways, including, but not limited to, contracting with a nurse triage service or assigning a health center provider to be on call. It is at the discretion of the health center to determine how after-hours calls are managed and the methodology used to inform patients of how to access care.  However, the health center must ensure information is provided to patients in language and literacy levels appropriate to the patient population.

When developing a documented policy/procedures for after-hours coverage, ensure the procedures address the following:

  • The applicability to all services in scope.  The process utilized for each service line (i.e., medical, dental, OB) must be clearly outlined.
  • The process used to provide after-hours coverage. Examples include a nurse triage line, extended health center hours, or an on-call provider.
  • A reasonable call back time to the patient.  Industry standard best practice is a maximum of 30 minutes.
  • The method used to notify patients of how to access after-hours coverage.  Examples include external and internal signage, patient handouts, or instructions on the health center’s main phone line.  The procedures should reflect the information is provided in language and literacy levels appropriate to the patient population.
  • The manner in which an after-hours call would be handled for the LEP patient population. Examples include the utilization of bi-lingual staff or a formal written contract with an interpreter service.
  • The process used for tracking after-hours call and how patient follow-up is managed.  

Health Centers can view other requirements for this chapter and evaluate compliance by answering the questions in the “Coverage for Medical Emergencies During and After-Hours” section of the HRSA Site Visit Protocol (Site Visit Protocol Medical Emergencies).

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