How Hospitals and Federally Qualified Health Centers Should Collaborate
4. Hospitals could vend back office and specialized resources to its FQHC partner, to provide IT, leadership development, finance, billing, general management, purchasing, human resources, benefits management and leased staff with customer service levels the public associates with hospitals. Hospitals could provide real estate, equipment, furnishing, or support an FQHC through back office services. FQHC savings by outsourcing back office and specialized resources to hospitals could be used to expand the FQHC's primary care reach.
5. Hospital ER staff could use an in-person and/or telephonic triage system, consistent with EMTALA's definition of "emergency" as qualified by the reasonable, prudent layperson standard, to refer patients who do not require an ER level of services to an FQHC.
6. Hospitals could let an FQHC co-locate its clinics adjacent to, or in close proximity to, a hospital's ER to take advantage of patient flow patterns, habits and expectations. An FQHC could provide registered patients with a medical home, provide preventive care, including medical, dental and behavioral healthcare, and manage chronic conditions. FQHC social workers could try to arrange for necessary follow-up care. FQHC' co-located clinics would have business hours and business days, including holidays, that overlap with the hours of highest frequency of hospitals' ER utilization.
FQHC co-located clinics would offer walk in urgent care in addition to scheduled appointments. Co-location would enable a FQHC to leverage critical conveniences from hospitals, such as prime locations on public transportation routes and language translation services. Co-location would provide FQHC patients with easy access to hospital pharmacies, from which FQHC patients could receive Section 340B drug pricing.
7. Hospitals and FQHC could expand the co-location model to include community mental health. Much avoidable ER use is by individuals with "crisis" behavioral health needs which are not life-threatening and do not require ER care. A partial list of these include: urgent medication management; intoxication; family crises; acute grief reaction; panic attacks; acute social issues (homelessness and lack of food); non-suicidal self-harm; etc. Hospital ER staff would assess mental health clients with medical co-morbidities who need differential diagnosis to ensure medical illnesses are not treated psychiatrically or vice versa.
After appropriate screening and stabilization, hospitals could offer to triage patients to the co-located behavioral health provider with follow up through a FQHC. Co-location could link crisis mental health and substance abuse behavioral services to primary care mental health and substance abuse services provided by an FQHC and expedite the establishment of medical homes for both primary medical care and behavioral health services.
8. Hospitals could convert some of their primary care locations to new FQHCs or merge them into an existing FQHC, with additional locations (especially for high risk activities such as obstetrics).
Pressure from declining reimbursements and an uptick in uncompensated care from avoidable ER visits compel hospitals to get savvy about addressing the root causes of avoidable ER visits. It is in hospitals' enlightened self interest to collaborate with FQHCs to support the continued growth of medical homes for patient populations that have demonstrated frequent use of a hospital ED as an alternative to primary care.
While stewarding overall community health resources through appropriate access and site of service, the actual health status of a community can be lifted by access to the comprehensive patient-centered, team oriented and holistic approach to health pioneered by FQHCs. Every hospital owes it to itself and to its community to help FQHCs thrive.
Susan Patton is a senior attorney based in the Ann Arbor, MI, office of the law firm Butzel Long. She may be reached at firstname.lastname@example.org or 313-225-7000.
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