Referral Tracking and How to Maintain Compliance

Effective management of referrals is a key component of care coordination and is essential to ensure patient continuity of care.  As outlined in “Chapter 4 – Required and Additional Health Services” (Chapter 4 – Required and Additional Health Services) and “Chapter 21 – Federal Tort Claims Act” (Chapter 21 – Federal Tort Claims Act) of the Health Center Compliance Manual, health centers must have a solid system in place for tracking referrals. 

Ensuring compliance requires a collaborative effort from both health center staff and the referral provider. If done efficiently, referrals provide important patient care recommendations that contribute to a patient centered model of care.  Unfortunately, oftentimes the referral process can cause frustration for all involved, including the patient. 

The following can help health centers not only ensure compliance, but also alleviate undue burden on the part of both health center staff and patients, as well as ensure the delivery of quality patient care.

  1. Develop a work group that includes all staff members who are involved in the referral tracking process.
  2. Evaluate the existing referral tracking process that is currently in place.  This should reflect the process as it is now, and not how staff members think it should be.
  3. Review the health center’s existing Referral Tracking and Laboratory/Diagnostic Testing Policies to ensure what is documented on paper reflects current practice. These policies should address the following:
    1. How the referral is initially made.
    2. The urgency level of the referral.
    3. Past and present clinical information that provides the rationale for the referral.
    4. The individual accountable for scheduling the appointment (i.e., specialist or patient).
    5. The staff, process and timelines involved with tracking of the referral.
    6. The responsibilities of the referral provider with regards to continuity of care.
    7. The process for patient follow-up.  
    8. The process and timelines for missed appointments.
    9. The assignment of a specific number of attempts to be made by staff following a missed appointment.
  4. Leverage technology to reduce the burden on staff and facilitate a seamless process.  Most Electronic Health Records have a referral tracking module for staff to utilize.
  5. Ensure closure of the referral loop.  This may involve utilizing health center resources to contact referral providers and track down the status of the referral.
  6. Include referral tracking metrics in the Quality Management Program to identify any gaps in the process.

Most importantly, the health center must ensure evaluation of the referral tracking process by incorporating referral tracking metrics into the Quality Management Program.  Metrics should be reported out a minimum of quarterly to ensure compliance with HRSA Quality Assurance/Improvement requirements, as well as FTCA Risk Management standards.  

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