PCMH & PCSP Multi-Site FAQs
Q: What is a multi-site application?
A: A multi-site application is an option for organizations or medical groups with three or more practice sites that share an electronic health record (EHR) system, as well as standardized policies and procedures across all practice sites.
If your organization is eligible for this option, you complete the same Survey Tools as individual site applicants but are relieved of repeating responses and documentation that would be the same at all sites. This is accomplished by completing an additional Admin Multi-Site Tool for shared responses and documentation.
Q: Some of our practice sites share the same systems/processes, but not all of them. We plan to implement the same systems/ processes across all sites in the future. Are we eligible for the multi-site process?
A: Probably. If three or more of your sites currently share systems/processes (and have for at least three months) when you complete the eligibility request, your organization will most likely be eligible for the multi-site process—but eligibility is determined by a recognition manager after you complete the multi-site request in the online application.
An organization with three or more sites sharing the same EHR or that is transitioning to a new EHR will be approved if the sites have been on the same EHR for a minimum of three months, as indicated in the Admin Multi-Site Tool. (The Practice Site Survey Tool may be submitted only after a site has used the same EHR for the required length of time.) Submission of Practice Site Survey Tools may be staggered for up to one year after submission of the Admin Multi-Site Tool, based on the EHR implementation dates.
- To include the element response and documentation in the Admin Multi-Site Tool, at least three practice sites must use the same systems/processes for at least three months. Organizations attest to this in the Survey Tool, and attest that all additional sites applying will be affiliated with that Admin Multi-Site Tool.
- To include the element response and documentation in a Practice Site Survey Tool, the organization does not submit the Survey Tool until the practice site has implemented the system/ process for at least three months. The organization attests that the systems/ processes have been in place for at least three months for that site.
For example: An organization has seven practice sites. Three sites use the same EHR and policies and procedures, and have for at least three months. The organization plans to implement the same EHR and policies and procedures at the remaining sites over the next several months.
- For the Admin Multi-Site Tool, the organization, attests that the EHR and policies and procedures have been in place for at least three months at the three sites and at the additional sites that will be affiliated with the Admin Multi-Site Tool.
- To include the element response and documentation in a Practice Site Survey Tool, the organization submits the tool when that site has implemented the EHR for at least three months, and attests that the EHR has been in place for at least three months.
Q: At our organization, some practice sites use one EHR and some use another EHR. Are we eligible for the multi-site application process?
A: Yes, but your organization will need separate multi-site Admin Multi-Site Tools and will submit site-specific tools for each practice site. There is no need to establish more than one account in the online application system.
For example: If three sites use EHR A and four sites use EHR B, provide one set of eligibility responses for sites using EHR A and one set of eligibility responses for sites using EHR B.
Q: Our organization has some adult practice sites and some pediatric practice sites. Will this affect the elements we can answer once for all sites?
A: Yes, it might affect the elements. If your organization has different systems, policies or reports for adult and pediatric populations, some elements may require site specific responses in the Practice Site Survey Tools. Discuss this during your multi-site eligibility call.
Q: Our organization has multi-specialty practice sites. May we use the same clinically important conditions or high-risk/complex patients across all practice sites?
A: This varies by organization. You have three options.
1. Your organization may elect to identify these for each practice site.
2. Your organization may elect to identify these across all sites that practice one specialty and another three conditions across the rest of the sites.
3. Your organization may identify these across all practice sites applying for recognition. Because several elements require site-specific responses based on the identified conditions, you should select conditions that apply to all sites, and where you will be able to respond to these elements for all sites.
Q. Our organization has multi-specialty practice sites (individual sites that see a combination of adult and pediatric patients). If the pediatric and adult processes/procedures differ, must we provide documentation for both populations?
A: Yes. Your practice site should provide documentation for both populations if processes/procedures differ.
Q: What are the criteria for completing our Admin Multi-Site Tool, as opposed to a site-specific Survey Tool?
A: You may need to move more elements to the Practice Site Surveys if criteria for a corporate response are not met. You may always answer an element at the practice-site level. Consider these criteria:
- You must orient/train staff by a standardized process in order to claim that a system is shared and used in the same way at all practice sites.
- You must include at least 12 elements for PCMH 2014.
- Eighteen PCMH 2014 elements may be responded to in the multi-site Admin Multi-Site Tool.
- If all practice sites do not address the same specialty and you have chosen different important conditions, you must respond to elements in the Practice Site Survey Tools that reflect activities related to the important conditions.
- If your organization creates a document that includes specific data (not aggregated data) for each identified site in one document, you must include that document in each practice site’s Survey Tool. Do not attach this document in the Admin Multi-Site Tool and do not include it in the Admin Multi-Site Tool and in the Practice Site Survey Tools.
- Failure to respond in the Practice Site Survey Tool or failure to provide site-specific documentation will result in a score of “zero” for the element.
- In the Admin Multi-Site Survey Tool, you must attest in the Organization Background, documentation or support text/notes box that all practice sites in your organization applying for recognition using the Multi-Site Survey Tool share the same policies, procedure, process or system.
- You must respond to an element in the Practice Site Survey Tool if you cannot attest and document the shared policy, procedure, process or system at all practice sites applying for recognition in the multi-site process. You may respond to an element in the Practice Site Survey Tool but you may not answer fully or partially in both the Admin Multi-Site Tool (primary) and the Practice Site Survey Tools.
Q: Under new multi-site policy announced Nov 16, 2015 pertaining to removal of the one year requirement of all sites being submitted after the corporate tool is finalized, what are the benefits?
A: Corporate data will no longer expire as it did after 1 year. All multi-site practice recognition's will now share the first recognized site’s 3-year end date. For example, if the first site has a recognition date of 12/16/2015-12/16/2018, all sites submitted using the corporate data within the 3year period or by 9/30/17, the last date to submit PCMH 2014 tools, will also have an end date of 12/16/2018. Each site’s start date may vary based on when the site’s review is completed (which may not be a full 3year period).
Q: Are there deadline dates for practices applying under the PCMH 2014 standards?
A: Practices that are initial or renewing applicants that are not ready to move to the new PCMH 2017 recognition model have the following important dates related the 2014 standards:
- 3/31/17 - Last day to purchase PCMH 2014 survey licenses
- 5/31/17 - Last day to submit Corporate Surveys
- 6/30/17 - Last day to request PCMH 2014 Add-on Surveys for any currently recognized or recently denied PCMH 2014 practice site
- 9/30/17 – Last day to submit any PCMH 2014 Site Surveys (including practice site Add-ons, conversions, renewals, initial individual and initial multi-site practice-level surveys).
Q: Our organization has many practice sites and plans to report PCMH 2014 Elements 3C, 4B and 4C using the Record Review Workbook. Each practice site uses the same processes and systems to document the information required by the elements – can we submit the same examples for each practice site?
A: Yes, as long as the practice sites use the same processes to complete the activities and the same systems to document the information for the comprehensive health assessment (3C), care planning (4B) and medication management (4C), it would be acceptable to provide the same examples for each factor in each site’s survey tool to accompany the Record Review Workbook. Please note, however, that each practice site needs to complete a site-specific Record Review Workbook sampling patients identified in Element 4A for each individual site, but to ease documentation burden for multi-site groups, NCQA will allow the same examples to be provided. The examples must be uploaded to each individual site’s survey tool for review in their respective elements. The practice should maintain a log of patients represented in the examples in the case of an audit.