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Nutritional Counseling & Form 5A

We provide nutritional counseling directly to our patients since we have a full-time nutritionist who works in our health center. We are seeing an increase in diabetic patients. Meanwhile, patient satisfaction survey results show that patients report long waiting times to get a nutritionist appointment. We are planning to establish a contractual relationship with a nutritionist who sees general patients in the community. We would pay for patients to see the contracted provider. Do we need to make any changes to our Form 5A since we provide the services directly and would be paying for patients to see the contracted nutritionist only if they can’t get a timely appointment? We aren’t scheduled for an OSV until next year.

 Yes.

The contractual relationship that you are describing is a Column II service delivery arrangement. This type of delivery method pays an individual who is not directly employed by the health center to provide a service to patients. You will need to submit a change in scope to add nutritional services as a Column II arrangement in addition to the existing Column I service delivery method. The services identified on Form 5A (B and C) represent your health center’s official scope of project and should always accurately reflect current operations. Note that health centers are free to make the business decision to provide required and additional services using more than one delivery method.

 

You mentioned that your OSV is scheduled for next year. Inaccuracies on Form 5A is a common source of non-compliance that gets identified during site visits. Hence, it is a good “housekeeping” rule to complete periodic reviews of Forms 5A (B and C) to make sure that they are accurate. See Chapter 4 of the Compliance Manual for more information.

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