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Quarterly Risk Assessments and Action Plans: Simplified Action Steps and Key Takeaways to Achieve FTCA Program Compliance

Quarterly Risk Assessments and Action Plans: Simplified Action Steps and Key Takeaways to Achieve FTCA Program Compliance

The current FTCA re-deeming application submission season is concluding. HRSA will communicate all re-deeming decisions once an application has been fully reviewed. Health centers that submit applications that demonstrate full compliance with the FTCA program will automatically receive medical malpractice coverage for 2027. HRSA will require health centers with non-compliant applications to achieve compliance before they grant next year’s coverage.

Quarterly risk assessments and actions plans are a common source of non-compliance. Let’s get ready for next year’s quarterly assessment and action plan completion by looking closer at the required elements where many applicants struggle.

Step One: Risk Assessment Scope

Choose at least one topic and provide a rationale regarding why the topic issue was chosen. The topic must focus on one clinical or patient safety issue that could lead to a medical malpractice claim that is covered by the FTCA program. Patient and/or employee safety issues tied to a health center’s building and/or parking lot features are not covered by the FTCA program. Identify purpose and goal (s) of the assessment.

Key Take-Away: Make sure you start with a topic that is eligible for FTCA coverage.

Step Two: Methodology

Briefly summarize the activities that were completed during the risk assessment. Describe data sources, individuals who participated in the assessment, and how the information was collected.

Key Take-Away: Make sure you discuss the process and rationale that resulted in the selection of the targeted risk topic. Focus on “what” you did.

Step Three: Risk Identification

Thoroughly describe how the targeted risk topic was identified, categorized, and prioritized. The discussion should include information regarding the risk topic and related issues that led to the observed failures; or that could lead to potential failures.

Key take away: Make sure that you provide a thorough discussion regarding how the risk(s) were identified. Focus on “how” you came to your decision.

Step Four: Risk Analysis

Thoroughly describe data analysis and assessment findings that are specific to the chosen risk topic. The description should include a discussion of factors that result in the identified risk along with any noted data trends. The description should also discuss the risk severity level that is associated with the chosen topic. i.e. low, medium, or high. The ECRI Risk Matrix is a good tool to use when discussing risk severity.

Key Take-Away: Make sure your description provides specific details that thoroughly summarize your risk analysis process and highlights the associated risk severity of the chosen topic. Focus on the data analysis and key findings.

Step Five: Risk Evaluation

Thoroughly describe the rationale that you used to prescribe the risk severity level, or prioritization for the identified risk topic. Discuss important factors that influence your risk severity rating decision. These factors can include issues such as costs, staffing shortages, and other concerns.

Key Take Away: Be very detailed in your discussion and provide as much specific information as possible regarding your prioritization decision making process.

Step Six: Action Plan

Describe and discuss activities and actions that were developed to resolve the identified risks. The activities should be corrective in nature and aimed at resolving the risk.

Key Take Away: Implemented activities should relate directly to the identified risks and reflect risk mitigation strategies.

Step Seven: Action Plan Monitoring

Describe the monitoring process to determine whether the implemented corrective action plan activities were effective. Monitoring activities and associated timelines should be included in your description.

Key Take Away: Quarterly risk assessments and action plans represent a closed loop process that starts with identifying risk topic and ends with monitoring outcomes after completing risk mitigation corrective activities.