Health Center Program Compliance Frequently Asked Questions (FAQ)
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The term “site visit” in these FAQ refers to:
- Operational Site Visits (OSVs) conducted for awardees
- OSVs conducted for look-alikes
- Initial Designation (ID) site visits conducted for look-alike applicants
The information in these FAQ only relates to requirements and processes of the HRSA Health Center Program.
Required and additional health services
This question relates to Element a. Providing and Documenting Services within Scope of Project
Transportation services enable patients to access health center services when transportation would otherwise be a barrier to care (for example, providing transport vehicles, bus tokens or vouchers for public transportation, or linkages to other community transportation programs).
To accurately document the provision of patient transportation services on Form 5A: Services Provided, refer to the following:
- Column I (Directly): If a health center provides its own transportation service or directly pays for transportation that enables patients to access health center services, record such transportation services in Column I. For example, the health center operates a patient transport vehicle, the health center purchases bus tokens/vouchers, or the health center arranges/pays for taxis.
- Column II (Formal Written Contract/Agreement): If a health center pays for transportation via a contract/agreement with another organization/entity, record these types of contracts/agreements in Column II. For example, the health center pays for transportation through an account with an entity such as Uber Health or a county senior van, the health center contracts with a local taxi company, or the health center has another contract for public transportation.
- Column III (Formal Written Referral Arrangement): If a health center has an arrangement for transportation with another organization/entity but is not paying for the service, record these types of arrangements in Column III. For example, the health center coordinates with or connects patients to community transportation programs but does not pay for the service.
For more information, refer to the Service Descriptors for Form 5A: Services Provided (PDF - 293 KB).
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
Nutrition education and counseling that are part of a primary care visit do not have to be listed separately on Form 5A: Services Provided because they are included within "General Primary Medical Care."
However, when nutrition education and counseling meet the definition for "Nutrition" in Service Descriptors for Form 5A: Services Provided (PDF - 293 KB) and are provided as a distinct service, then a health center would list "Nutrition" on Form 5A: Services Provided.
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
Screening services are performed based on identified risk factors in the community or patient population. At a minimum, these services must include screenings for all of the following: cancer, communicable disease, cholesterol, and blood lead. For more information, refer to the Service Descriptors for Form 5A: Services Provided (PDF - 293 KB) for what, at a minimum, must be included as part of each required service.
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
Yes, a health center is required to provide screening services to established patients and other individuals who present for and meet the criteria for screening, regardless of ability to pay. The provision of screening services should be based on identified risk factors in the patient population or community. Screening services include, but are not limited to, testing for HIV, Hepatitis B and C, and other sexually transmitted diseases/infections based on a patient's identified risk factors.
For more information on delivering services in the Health Center Program scope of project, refer to BPHC's Scope of Project page.
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
No, contracts/agreements or referral arrangements for enabling services do not need to include all of the provisions required for clinical services, such as documentation in the patient record or follow-up care. This is because enabling services, including transportation, translation, and outreach, are generally not documented in the patient record nor do they involve follow-up care; therefore, related provisions would not be included in the associated contract/agreement or referral arrangement.
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
If a health center contracts with an answering service that does not provide any clinical advice or medical triage, the service is not recorded on Form 5A: Services Provided for the purposes of after-hours coverage. In such cases, the answering service is not an actual health care service because the only role of the answering service is to connect a patient to an individual with the qualifications and training necessary to exercise professional judgment in assessing a health center patient's need for emergency medical care.
However, if a health center contracts with an answering service that provides medical triage or advice (for example, a nurse hotline), then "Coverage for Emergencies During and After Hours" is recorded in Column II of the health center's Form 5A: Services Provided. Refer to the Health Center Program Compliance Manual Chapter 7: Coverage for Medical Emergencies During and After Hours for additional information.
(Added: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
Yes, if a service is not identified on Form 5A in Columns II or III, this would be a finding of scope inaccuracy. A health center should review its Form 5A for accuracy in preparation for an operational site visit to ensure all contracted or referral services are correctly recorded on Form 5A. Refer to the Health Center Self-Assessment Worksheet for Form 5A: Services Provided (PDF - 3 MB) in preparation for an operational site visit.
(Updated: 3/8/2023)
This question relates to Element a. Providing and Documenting Services within Scope of Project
Yes, if a contract/agreement is misclassified as a referral arrangement or vice versa, then the site visit team would review the documentation based on what the appropriate column should be. The site visit team would record any non-compliance findings related to provisions that may be lacking from the contract or arrangement in the site visit report.
(Updated: 3/8/2023)