The Centers for Medicare and Medicaid Services (CMS) has recently posted new Question & Answers regarding the Community-Based Care Transitions Program.
One such question that has emerged from multiple home health agencies concerns what constitutes a “community-based organization” or CBO. See below for a pair of Q&A’s offering guidance:
- Q: Does a home health provider qualify as a Community-Based Organization (CBO)?
- A: A home health agency would only qualify as a CBO if it was based in the community it proposed to serve and had a governing body with broad community representation of multiple health care stakeholders, including consumers. To ensure broad stakeholder involvement, 50% of the board representation should come from outside the home health agency. Please also see our response to FAQ# 10418 for guidance on consumer representation.
- Q (#10418 from above): Does a coalition representing a collaboration of community healthcare providers (medical centers, Federal Qualified Health Centers (FQHCs), health plans, educational leaders and local government) qualify as a Community-Based Organization (CBO)?
- A: If the coalition is (1) a legal entity, such as a 501(c) (3) organization or other organization that has a taxpayer identification number and can accept payment, (2) has a governing body that includes broad community representation of multiple health care stakeholders, including consumers and (3) is physically located in the community it proposes to serve, then it could qualify as a CBO. In addition, there must be adequate consumer representation on the governing board with voting rights. The consumers may not be providers or immediate family members of providers to satisfy this requirement.
See the full list of Q&A’s relative to this program here.
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