FQHC implementation guide

Start with one accountable operating model.

Kept Count is configured around your team, policy, EHR, and billing authority. Implementation moves through visible gates before a bounded first cohort goes live.

The launch principle

Configure. Prove. Approve. Then activate.

No EHR replacement projectNo PHI during public evaluationNo automatic claims submissionNo launch without owner sign-off

The implementation sequence

Five phases with a concrete output at every step.

  1. 01

    Align the operating model

    Choose the first patient cohort, programs in scope, practice-led versus IHA-supported staffing, and the outcomes the launch must prove.

    Output

    Scope brief and named owners

  2. 02

    Configure the guardrails

    Map consent, clinical supervision, exceptions, documentation, patient communication, QA, security, and billing review to practice policy.

    Output

    Approved workflow and control map

  3. 03

    Validate with synthetic data

    Run the end-to-end journey—from panel review through the billing-support packet—without real patient information.

    Output

    Acceptance evidence and open-issue log

  4. 04

    Clear the production gates

    Complete contracting, BAAs, covered-environment controls, role provisioning, training, escalation coverage, and sign-off.

    Output

    Documented go-live decision

  5. 05

    Launch a bounded first cohort

    Activate the agreed cohort, monitor exceptions and quality, review evidence with leadership, and expand only after the practice accepts the results.

    Output

    Measured operating review

Ownership

The right people are in the room before configuration begins.

One person may hold more than one role in a smaller organization. What matters is that each decision has a named owner and backup.

Executive sponsor

Sets the outcome, removes blockers, and makes the final launch decision.

Clinical lead

Approves care protocols, supervision, escalation boundaries, and clinical acceptance.

Operations lead

Owns staffing, daily workflow, training, service levels, and issue resolution.

Compliance / privacy / security

Reviews consent, access, data flow, incident response, and production gates.

Billing / RCM lead

Confirms coding, evidence standards, held-line review, and final claims authority.

IHA implementation lead

Coordinates configuration, training, acceptance evidence, and launch support.

Decisions for the first working session

Six questions turn interest into a launchable plan.

You do not need every answer before the first conversation. These are the decisions the implementation process will make explicit.

First cohort
Which patients and locations create a bounded, representative starting point?
Program scope
Which care-management programs are in scope, and which are explicitly out?
Staffing model
Will your staff operate the workflow, will IHA add navigator capacity, or will responsibilities be shared?
Clinical escalation
Who receives each category of exception, through which channel, and on what response expectation?
Documentation standard
What must be present before work is considered complete or review-ready?
Claims release
Who reviews evidence, resolves held lines, chooses final codes, and authorizes submission?

What “ready” means before real-data use.

Readiness is evidence, not a date on a calendar. The practice accepts the workflow after the people, controls, and environment perform as agreed.

  • A representative patient journey completes from identification through review-ready evidence
  • Consent, assignment, escalation, QA, and held-line behavior match approved practice policy
  • Every role can perform its work and cannot access work outside its authority
  • Clinical and operational owners can find unresolved exceptions and their assigned owners
  • Billing can trace the support and review history behind each proposed line
  • The practice documents approval—or records exactly what must change before approval

Map one real-world FQHC scenario together.

Bring your panel range, current programs, staffing approach, EHR, and biggest implementation concern. Do not include patient information.