FUHN clinics leverage a shared risk management expert to strengthen clinical operations and patient care

Kristie Sams, MBA, CCMP, FMVA, LBBP, ESG, CBCP, may not have a clinical background, but she brings expertise in what she does best: helping organizations mitigate risk. A consultant with Creative Planning Business Services, she brings deep experience to the Federally Qualified Health Center Unified Health Network as a fractional director of risk management for four of FUHN’s member FQHCs.

One of the many benefits of FUHN, a clinically integrated health network, is that member FQHCs can leverage needed expertise from subject matter experts that individually small independent FQHCs would struggle to attract and sustain.

What is risk management and why it matters

Risk management in Health Resources and Services (HRSA)-funded FQHCs is a mandatory, ongoing process crucial for maintaining Federal Tort Claims Act (FTCA) malpractice coverage. FQHCs must conduct, document, and report quarterly risk assessments covering clinical care, high-risk services, patient safety, and incident reporting with a dedicated risk manager. 

Key Aspects of FQHC Risk Management:

• FTCA Compliance: FQHCs must submit annual deeming (renewal) applications, ensuring they have a comprehensive risk management program.

• Quarterly Risk Assessments: Risk assessment is a continuous process—not just a checklist—requiring the identification of risks and action plans that address the gamut of risks inherent in a clinical care workplace.

• Essential Components: Programs must include credentialing and privileging, patient confidentiality (HIPAA), infection control, medication management, and tracking of diagnostic tests.

• Training Requirements: Mandatory, tailored training for staff and board members is required to prevent adverse events.

• Incident Management: An active system for documenting and responding to patient incidents and claims is essential. 

Over the past few years, the FTCA Division of HRSA has increased the number of warning notices to FQHCs. In the process, many FQHC leaders realized they needed to improve their quarterly risk assessments to better demonstrate that they provide safe, effective, and reliable patient care, as most do.

For Sams, her philosophy is “risk management is a proactive system focused on identifying where breakdowns can occur and building controls that prevent them from reaching the patient.” When it comes to patients, everything is clinical to Sams.

Bringing expertise to FUHN members

Since working with FUHN members, Sams has determined that “what tends to vary across centers isn’t the type of risk; it’s the reliability and visibility of the processes managing that risk.” She says her role is to “bring consistency where it matters without adding unnecessary operational burden.”

Sams is not just managing the isolated activities around risk management; she’s guiding the member clinics to create structured, defensible programs as required by HRSA and FTCA. When she was a chief operating officer, she led post-acquisition integration of processes, balancing the current situation of multiple companies with what was operationally realistic for the respective teams.

“What is realistic operationally is different across the FUHN clinics because they vary in patient volume, staffing, and scale, so the approach has to be tailored to what each team can sustain,” says Sams. “Across all four clinics, there is a strong commitment to patient care and a clear focus on improving the structure and consistency of risk management.”

Health care is human, so failure happens. For Sams, the goal isn’t to respond to incidents when they happen; it’s to examine and build or fine-tune the controls around potential occurrences.

With her varied leadership experience, including as a former chief financial officer, Sams’s lens is broader than operations and process.

“In my career, I’ve found that operational decisions are often made in the moment, but not always evaluated against their longer-term cost impact,” says Sams. “I evaluate decisions through a ‘COI’ or ‘Cost of Inaction’ lens—or what happens if an issue isn’t addressed, not just what it costs to fix it.”

Given increased scrutiny by HRSA and FTCA of quarterly risk assessments, the ‘Cost of Inaction’ around risk management is too great. Kudos to the clinics that are digging into improving their documentation and processes.

Benefits of shared services agreements

FUHN’s executive director, Mary Maertens, RN, PHN, MHA, FACHE, and Sams have both built and leveraged shared services agreements throughout their careers. FUHN’s establishment as a “clinically integrated network” allows the organization to enter into contracts as a network and act as a management services organization for its members.

“A key benefit of a shared services agreement is having access to a subject matter expert like Kristie and financially spreading that cost across multiple clinics,” says Maertens. “The best consultants examine each clinic and tailor their recommendations to the respective needs, size, experience, and staffing considerations of the clinics involved. A shared services arrangement works well if you have the right partner, and we do with Kristie.”