Compliance Corner November 2023

Newly Released National Survey of Children’s Health

October 2023:  HRSA released the newest National Survey of Children’s Health (NSCH) Data.  Watch their new 80-second video to learn about the NSCH and its value to our nation and access the latest data brief, Material Hardship Among Children, 2022.  The NSCH is the largest national- and state‐level survey on the health and well‐being of children, their families, and their communities, providing timely information and comprehensive data on a range of topics such as:

  • prevalence and impact of special health care needs
  • healthcare quality and access
  • physical and mental health
  • adverse childhood experiences
  • *NEW* in the 2022 NSCH are data related to healthy and ready to learn, housing instability, eating and weight related behaviors and concerns, fetal alcohol syndrome disorder diagnosis and evaluation, and receipt of supplemental security income.

This data is essential to understanding the health status and health services needs of children across the nation and in your state and community. Contact HRSA for assistance with tailoring content and messaging for presentations, blog posts, or newsletters that address particular topic areas. Send any requests for assistance to

Source: HRSA

340B Registration Requirements for Off-site, Outpatient Hospital Facilities

The Health Resources and Services Administration released a Federal Register Notice to inform and remind stakeholders of the registration requirements for off-site, outpatient hospital facilities to participate in the 340B Drug Pricing Program.

As part of the government’s efforts to respond to the unprecedented circumstances of the COVID-19 Public Health Emergency, HHS allowed various flexibilities across many of the Department’s programs, including the 340B Program. This included waiver of longstanding requirements that off-site, outpatient hospital facilities be (1) listed as reimbursable on the hospital’s Medicare Cost Report prior to participating in the 340B Program; and (2) registered and listed in 340B Office of Pharmacy Affairs Information System (OPAIS) prior to participating in the 340B Program. This waiver was available as of June 2020 only for off-site, outpatient facilities that would be listed as reimbursable on a future Medicare Cost Report. 

The waiver was implemented in recognition of the need for hospitals to quickly respond to the rapidly evolving conditions of the COVID-19 pandemic and assist in creating efficiencies for hospitals to adjust operations in that response. For example, some hospitals moved clinics outside the four walls of a hospital building to expand capacity for care for patients with COVID-19 or transitioned certain clinic functions to meet the needs of the patients, such as by shifting an outpatient surgery center to serve as an urgent care or emergency room. 

Pandemic conditions are no longer rapidly evolving in a manner that requires significant unplanned activities or changes by hospital covered entities to accommodate these exigencies.  Additionally, HRSA program integrity efforts have demonstrated that the waiver has added risk and complexity to HRSA’s ability to effectively oversee compliance in the 340B Program. HRSA issued this Notice to better address these risks.

Source: HRSA

Promoting Oral Health in Schools: Resource Guide

Schools are ideal settings in which to reach children and adolescents and, through them, their families. The National Maternal and Child Oral Health Resource Center (OHRC) produced Promoting Oral Health in Schools: A Resource Guide to provide information about materials for promoting oral health in schools. The guide features materials on: data and surveillance; policy; professional education, tools, and training; program development; and, public education. Selected materials include a toolkit to help improve the quality of school meals, best practice reports about school-based dental sealant programs and about use of fluoride in schools, and a curriculum for students in kindergarten through grade 10.

Source: OHRC

Recovering from a Cybersecurity Attack and Protecting the Future in Small, Rural Health Organizations

A new feature article in The Rural Monitor examines the increasing incidence of cyber attacks on healthcare organizations and the particular vulnerability of rural providers.  According to the Cybersecurity Program at the U.S. Department of Health & Human Services, 60 percent of ransomware attacks – whereby bad actors gain entry to an organization’s online system and lock critical files until a ransom is paid – were aimed at healthcare systems in 2020. FORHP-supported research out last year found that rural hospitals are less likely to be attacked, but staff are less equipped to handle them when they do happen, and rural residents who need these services have fewer alternatives for care.

Source: FORHP

HRSA Celebrates National Rural Health Day

Join HRSA on Thursday, November 16, at 11 a.m. ET for a discussion with federal leaders highlighting innovations in rural health care delivery.  Other events throughout the week include a virtual HRSA rural job fair, a podcast discussion highlighting a successful rural program and much more.  Click HERE for more information.

Source: HRSA

Prescribing Controlled Medications Via Telehealth

The Drug Enforcement Administration (DEA), jointly with the Department of Health and Human Services (HHS), has extended the full set of telemedicine flexibilities regarding the prescribing of controlled medications as were in place during the COVID-19 public health emergency (PHE), through December 31, 2024.  Learn more HERE.

Source:  HRSA Office for the Advancement of Telehealth

2023 Ryan White HIV/AIDS Program Biennial Report Now Available

HRSA’s HIV/AIDS Bureau (HAB) is excited to share that the 2023 Ryan White HIV/AIDS Program Highlights biennial report is now available. To highlight innovative models of HIV care and treatment that Ryan White HIV/AIDS Program and HAB Ending the HIV Epidemic in the United States (EHE) initiative recipients implement in communities across the country, HRSA HAB publishes a report every two years. These reports provide an update of Ryan White HIV/AIDS Program and HAB EHE efforts to improve health outcomes for people with HIV and document the successes and challenges of recipients.  Access the report here:  Harnessing the Power of Community Engagement and Innovation to End the HIV Epidemic: 2023 Ryan White HIV/AIDS Program Highlights.

Source:  HRSA HIV/AIDS Bureau

Medicare: Complying with Medical Record Documentation Requirements

CMS has amended its Fact Sheet on “Complying with Medical Record Documentation Requirements”.   Review MLN909160 HERE

Source:  MLN

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