X Background: In 2014, the Office of Population Affairs (OPA) released updated X family planning program guidelines, hereafter referred to as “The Guidelines.” These Guidelines consist of two parts: The Title X Program Requirements, which lays out the Federal statutory and regulatory requirements of the Title X program. Providing Quality Family Planning Services: Recommendations of CDC and the U.S. Office of Population Affairs (QFP), which provides clinical recommendations for how to provide family planning services in a manner that is consistent with the best available scientific evidence. While this tool is intended for use by Office of Population Affairs staff and consultants, it may also be used by Title X grantees as a self-assessment and can also be adapted for use by grantees for monitoring their sub-recipients and service sites. The tool describes strategies that grantees may use to operationalize applicable Title X statutory and regulatory requirements and lays out the minimum expectations for compliance. The document also illustrates how a grantee can implement QFP in a way that ensures quality care is provided throughout the Title X project. This tool focuses on Sections 8-13 of the Program Requirements because these are the sections that outline the key operational elements of a Title X family planning services project. In cases where the grantee relies on other entities (sub-recipients) for the provision of family planning services, the grantee is responsible for ensuring that sub-recipients are in compliance with the Title X program requirements. Scoring Instructions: There are two types of assessments that will be generated by OPA upon completion of the program review tool: Title X Program Requirements Assessment: Met/Not Met/N/A
A Site A: ___ Site B: ___ Site C: ___ Documentation at the service site(s) (e.g., staff circulars, training curriculum) indicates staff has been informed at least once during the current project period that a client’s receipt of family planning services may not be used as a prerequisite to receipt of any other services offered by the service site. A Site A: ___ Site B: ___ Site C: ___ Administrative policies at service include a written statement that receipt of family planning services is not a prerequisite to receipt of any other services offered by the service site. A Site A: ___ Site B: ___ Site C: ___ General consent or other documentation provided to clients states that receipt of family planning services is not a prerequisite to receipt of any other services offered by the service site. C Site A: ___ Site B: ___ Site C: ___ Medical record review demonstrates that each client has signed a general consent form stating receipt of family planning services is not a prerequisite to receipt of any other services offered. Section 8.1.3: Personnel Awareness Personnel working within the family planning project must be informed that they may be subject to prosecution if they coerce or try to coerce any person to undergo an abortion or sterilization procedure (Section 205, Public Law 94-63, as set out in 42 CFR 59.5(a)(2) footnote 1). Reviewer Code Met Not Met Sub-Recipient/ Service Site Implementation Strategy Comments A Grantee has written policies and procedures that require that all staff of the grantee, sub-recipients, and service sites is informed that they may be subject to prosecution if they coerce or try to coerce any person to undergo an abortion or sterilization procedure. A Documentation at the grantee level demonstrates that staff has been informed at least once during the current project period that they are subject to this requirement. A Site A: ___ Site B: ___ Site C: ___ Documentation at sub-recipients and service (e.g., staff circulars, training records) demonstrates that staff has been informed at least once during the current project period that they are subject to this requirement. 8.1 Additional Comments: [e.g., “Met 10 out of 10 requirements”]
A Site A: ___ Site B: ___ Site C: ___ A patient bill of rights or other documentation which outlines client’s rights and responsibilities. 9.2 Link to QFP: Cultural Competency and Client Dignity A core premise of Recommendations for Providing Quality Family Planning Services is that quality services are client-centered, which includes providing services in a respectful and culturally competent manner. Reviewer Code Evidence of Quality Indicator in Place? Quality Indicator Comments A Yes No The grantee needs assessments or other documentation (including those of the sub-recipients) describe populations that may be in need of culturally competent care. A Yes No The grantee has written policies and procedures that require their sites and sub-recipients to receive training in culturally competent care. This should include how to meet the needs of the following key populations: LGBTQ, adolescents, individuals with limited English-proficiency, and the disabled. A Yes No Documentation (e.g., training records) that demonstrates staff have received training in providing culturally competent care to populations identified in the needs assessment. A Yes No Observation of the clinic environment demonstrates that it is welcoming (i.e., Privacy, cleanliness of exam ease of access to service, fair and equitable charges for services including waiver of fees for “good cause,” language assistance). A Yes No Client surveys document that clients perceive providers and other clinic staff to be respectful. A Yes No + Additional quality indicators, best practices, or highly innovative approaches If Yes, describe: 9.2 Quality Assessment Score: Exceptional (All 5 Quality Indicators Evident + Best Practices In Place) Good (3 – 5 Quality Indicators Evident) Fair (1 – 2 Quality Indicators Evident) 0 Quality Indicators Evident 9.2 Additional Comments: 9.3: Non-Discriminatory Services
Services must be provided without regard to religion, race, color, national origin, disability, age, sex, number of pregnancies, or marital status (42 CFR 59.5 (a)(4)). Reviewer Code Met Not Met Sub-Recipient/ Service Site Score Implementation Strategy Comments A Grantee has written policies and procedures that require their service sites and any sub-recipient sites to provide service without regard to religion, race, color, national origin, disability, age, sex, number of pregnancies or marital status, and to inform staff of this requirement on an annual basis. A Documentation (e.g., staff circulars, orientation documentation, training curricula) demonstrates that staff has been informed at least once during employment that services must be provided without regard to religion, race, color, national origin, disability, age, sex, number of pregnancies or marital status. A Question N/A (No Grantee has documentation of monitoring of sub-recipients for compliance with non-discrimination requirements. 9.3 Additional Comments: 9.4: Availability of Social Services Projects must provide for social services related to family planning including counseling, referral to and from other social and medical services agencies, and any ancillary services which may be necessary to facilitate clinic attendance (42 CFR 59.5 (b)(2)). Reviewer Code Met Not Met Sub-Recipient/ Service Site Score Implementation Strategy Comments A The grantee’s needs assessment or other activities has documented the social service and medical needs of the community to be served, as well as ancillary services that are needed to facilitate clinic attendance, and identified relevant social and medical services available to help meet those needs.
Good (2 – 3 Quality Indicators Evident) Fair (1 Quality Indicator Evident) 0 Quality Indicators Evident 9.6 Additional Comments: 9.7: Provision of Family Planning and Related Services All projects must provide for medical services related to family planning and the effective usage of contraceptive devices and practices (including physician’s consultation, examination, prescription, and continuing supervision, laboratory examination, contraceptive supplies) as well as necessary referrals to other medical facilities when medically indicated (42 CFR 59.5(b)(1)). This includes, but is not limited to emergencies that require referral. Efforts may be made to aid the client in finding potential resources for reimbursement of the referral provider, but projects are not responsible for the cost of this care. Reviewer Code Met Not Met Sub-Recipient/ Service Site Score Implementation Strategy Comments C The grantee has written policies and procedures requiring sub-recipients and service sites to provide medical services related to family planning as indicated in this section. This should also be included in sub-recipient contracts. C Site A: ___ Site B: ___ Site C: ___ Current written (i.e., updated within the past 12 months) clinical protocols clearly indicate that the following services will be offered to female, male and adolescent clients as appropriate: a broad range of contraceptives, pregnancy testing and counseling, services to assist with achieving pregnancy, basic infertility services, STD services, and preconception health services. C Site A: ___ Site B: ___ Site C: ___ Breast and cervical cancer screening are available on-site and offered to female clients. C Site A: ___ Site B: ___ Site C: ___ Written collaborative agreements with relevant referral agencies exist, including: emergency care, HIV/AIDS care and treatment providers, infertility specialists, primary care and chronic care management providers. C Site A: ___ Site B: ___ Site C: ___ Medical records document that clients are provided referrals when medically indicated. 9.7 Additional Comments:
9.11 Additional Comments: 9.12: Compliance with Legislative Mandates Title X grantees must comply with applicable legislative mandates set out in the HHS appropriations act. Grantees must have written policies in place that address these legislative mandates: “None of the funds appropriated in the Act may be made available to any entity under Title X of the Public Health Service Act unless the applicant for the award certifies to the Secretary of Health and Human Services that it encourages family participation in the decision of minors to seek family planning services and that it provides counseling to minors on how to resist attempts to coerce minors into engaging in sexual activities.” “Notwithstanding any provision of law, no provider of services under Title X of the Public Health Service Act shall be exempt from any State law requiring notification or the reporting of child abuse, child molestation, sexual abuse, rape, or incest.” Reviewer Code Met Not Met Sub-Recipient/ Service Site Score Implementation Strategy Comments A The grantee has written policy and procedures requiring their sites and all sub-recipients to inform their staff periodically that: (a) clinic staff must encourage family participation in the decision of minors to seek FP services, (b) minors must be counseled on how to resist attempts to coerce them into engaging in sexual activities, and (c) State law must be followed requiring notification or the reporting of child abuse, child molestation, sexual abuse, rape, or incest. Grantee contracts with sub-recipients include these requirements. A Site A: ___ Site B: ___ Site C: ___ Documentation (e.g., staff circulars, training curricula) demonstrates that all staff has been formally informed about items 1a-c above at least once during the current project period. C Site A: ___ Site B: ___ Site C: ___ Medical records of minors document encouragement regarding family participation in their decision to seek family planning services and counseling on how to resist attempts to being coerced into engaging in sexual activities. 9.12 Additional Comments:
Projects must establish and implement planned activities to facilitate community awareness of and access to family planning services (42 CFR 59.5(b)(3)). Each family planning project must provide for community education programs (42 CFR 59.5(b)(3)). The community education program(s) should be based on an assessment of the needs of the community and should contain an implementation and evaluation strategy. Reviewer Code Met Not Met Sub-Recipient/ Service Site Score Implementation Strategy Comments A Documentation demonstrates that the grantee conducts periodic assessment of the of the community with regard to their awareness of and need for access to family planning services. A Grantee has a written community education and service promotion plan that has been implemented (e.g., spots/materials developed, event photos, participant logs, and monitoring reports). The plan: (a) states that the purpose is to enhance community understanding of the objectives of the project, make known the availability of services to potential clients, and encourage continued participation by persons to whom family planning may be beneficial, (b) promotes the use of family planning among those with unmet need, (c) utilizes an appropriate range of methods to reach the community, and (d) includes an evaluation strategy. A Documentation that evaluation has been conducted, and that program activities have been modified in response. 11.2 Additional Comments: 11.3: Community Education Community education should serve to enhance community understanding of the objectives of the project, make known the availability of services to potential clients, and encourage continued participation by persons to whom family planning may be beneficial (42 CFR 59.5 (b)(3). Reviewer Code Met Not Met Sub-Recipient/ Service Site Implementation Strategy Comments
A / C Yes No + Additional quality indicators, best practices, or highly innovative approaches If Yes, describe: 13.1 Quality Assessment Exceptional (All 5 Quality Indicators Evident + Best Practices In Place) Good (3 – 5 Quality Indicators Evident) Fair (1 – 2 Quality Indicators Evident) 0 Quality Indicators Evident 13.1 Additional Comments: 13.2: Emergency Management All grantees, sub-recipients and Title X clinics are required to have a written plan for the management of emergencies (29 CFR 1910, subpart E) and clinical facilities must meet applicable standards established by Federal State and local governments (e.g. local fire, building, and licensing codes). Reviewer Code Met Not Met Sub-Recipient/ Service Site Implementation Strategy Comments A Grantee disaster plans have been developed and are available to staff. A Site A: ___ Site B: ___ Site C: ___ Staff can identify emergency evacuation routes. A Site A: ___ Site B: ___ Site C: ___ Staff has completed training and understands their role in an emergency or natural disaster. A Site A: ___ Site B: ___ Site C: ___ Exits are recognizable and free from barriers. A Grantee documentation demonstrates oversight of and service sites compliance with these requirements. 13.2 Additional Comments: 13.3: Standards of Conduct Projects are required to establish policies to prevent employees, consultants, or members of governing/advisory bodies from using their positions for purposes that are, or give the appearance of being motivated by a desire for private financial gain for themselves or others (HHS Grants Policy Statement 2007, II-7).