Health Center Program Compliance Frequently Asked Questions (FAQ)

If a health center needs to make a change to its scope of project, the health center must submit a CIS request through the Electronic Handbooks (EHBs). This allows HRSA to review and approve the change. There are two kinds of CIS requests:

• Formal- a formal CIS is for a significant change.
• Scope Adjustment- a scope adjustment is for a smaller change.

Formal CISs include:

• Add a new, additional, or specialty service to scope
• Delete an existing service from scope
• Add a new service site to scope
• Convert an existing administrative-only site to a service/administrative site or a service site
• Delete an existing service site from scope
• Convert an existing service site or service/administrative site to an administrative-only site
• Add a new target population

Scope Adjustments include:

• Update a required service
• Update an additional or specialty service
• Add an administrative-only site
• Delete an administrative-only site
• Update information about a site (such as hours of operation, months of operation, zip codes)
• Add, remove, or update other activities/locations

There are some updates to scope that are done by a health center through the self-update module within the EHBs. HRSA does not review these submissions.

Self-Updates include:

• Site name
• Service delivery site type (can only switch between administrative/service delivery site and service delivery site)
• Web URL
• Site phone number
• Site setting
• FQHC site National Provider Identification (NPI) number
• FQHC site Medicare billing number status
• FQHC site Medicare billing number

(Updated: 3/8/2023)

No, a change not listed under Formal CIS, Scope Adjustment CIS, or Self-Updates, as described in the "What is a Change in Scope (CIS) request?" FAQ, does not require the submission of a CIS into the Electronic Handbooks (EHBs).

Examples of changes that do not require HRSA approval may include, but are not limited to, hiring a new provider for a service already in scope or expanding in-scope services at other existing sites. For more information about scope, refer to the Scope of Project webpage.

(Updated: 3/8/2023)

A health center should submit a CIS request at least 60 days before the health center plans to implement the change.

(Updated: 3/8/2023)

1. Review PIN 2008-01: Defining Scope of Project & Policy for Requesting Changes (PDF) and PAL 2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines (PDF - 126 KB).
2. Use the sample forms and instructions found on the Scope of Project Resources webpage as a guide to complete the CIS.
3. Submit any questions through the BPHC Contact Form.
4. Complete and submit the official forms through the Electronic Handbooks (EHBs).

(Updated: 3/8/2023)

HRSA may take up to 60 days to review and approve a CIS, and HRSA may return any submission that needs corrections. Once a health center resubmits a CIS, HRSA may take another 60 days to review and approve it. In unique cases, HRSA may extend the review period beyond 60 days.

If HRSA approves a Formal CIS, the health center will receive a Notice of Award (NoA) or Notice of Look-Alike Designation (NLD). The health center then has 120 days to implement the change (for example, opening a health center site or beginning to provide a new health care service). When the change in scope is implemented by the health center, the health center must submit a Scope Verification task in the Electronic Handbooks (EHBs). Once HRSA accepts the verification, HRSA will issue a new NoA or NLD confirming the updates to the health center's scope of project.

Although HRSA does not issue a NoA or NLD for Scope Adjustment CISs or Self-Updates, the health center's scope of project updates in the EHBs. For additional information, refer to PAL 2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines (PDF - 126 KB).

(Updated: 3/8/2023)

A health center should refer to the Scope of Project Resources webpage to learn more about the CIS process. Some resources apply to all CIS requests; others are specific for changes to services, sites, target populations, or other activities.

(Updated: 3/8/2023)

A health center must contact HRSA as soon as possible but no later than 15 calendar days after initiating emergency response activities at the location. HRSA will determine on a case-by-case basis whether extraordinary circumstances justify an exception to the 15-day requirement.

A health center should use the BPHC Contact Form (preferred) or e-mail BPHCOHCPMHCESupport@hrsa.gov to submit a temporary service site request. To submit a request on the BPHC Contact Form, a health center awardee or look-alike should:

1. Go to the "Program Monitoring H80" section;
2. Select "General H80 Award;" and
3. Select "Temporary Site Request (Emergency Need)" in the dropdown menu.

If a health center is unable to access the BPHC Contact Form or to e-mail BPHCOHCPMHCESupport@hrsa.gov, a health center should contact Health Center Program Support at 1-877-464-4772.

To learn more about what a health center must submit to HRSA in the request, refer to PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 266 KB).

(Updated: 3/8/2023)

A health center must contact HRSA to request approval for an extension of time beyond 90 days. Otherwise, HRSA's approval of a temporary service site will automatically expire 90 days after the temporary service site's approved effective date, regardless of the issue date of formal documentation, and HRSA will administratively remove the temporary service site from the health center's scope of project.

A health center should use the BPHC Contact Form (preferred) or e-mail BPHCOHCPMHCESupport@hrsa.gov to submit an extension request. To request an extension using the BPHC Contact Form, a health center awardee or look-alike should:

1. Go to the "Program Monitoring H80" section;
2. Select "General H80 Award;" and
3. Select "Temporary Site Request (Emergency Need)" in the dropdown menu.

If a health center is unable to access the BPHC Contact Form or to e-mail BPHCOHCPMHCESupport@hrsa.gov, a health center should contact Health Center Program Support at 1-877-464-4772.

To learn more about temporary service site requests, refer to PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 266 KB).

(Updated: 3/8/2023)

Health centers can provide services to their patients and other residents of their service area at locations outside the health center, such as homeless encampments, parks, and under bridges. Providing care in this way enables individuals experiencing homelessness and others who may avoid medical treatment or face barriers to accessing medical treatment in traditional care settings to access care. We consider these activities to be in your scope of project if: 

1. You provide services documented on your Form 5A: Services Provided; 
2. Your health center providers (employees, volunteers, or contractors) deliver the services; and 
3. You document the services you provide in a health center patient record.

You can document that you provide services through street medicine in your health center’s scope of project by: 

• Ensuring that you have documented any services you provide through street medicine on your Form 5A: Services Provided (PDF - 63 KB); and
• Documenting these activities on Form 5C: Other Activities/Locations (PDF - 113 KB) by checking “Portable Clinical Care” in the list of Activity Types/Locations. 

See PIN 2008-01 – Defining Scope of Project and Policy for Requesting Changes (PDF) for additional information. 

You should ensure that you obtain appropriate informed consent prior to providing care. You should also have policies and procedures in place regarding what clinical services your staff can and cannot provide at the locations where you provide services through street medicine.

For information about FTCA requirements, refer to the FTCA Health Center Policy Manual (PDF - 406 KB), including sections C. Covered Activities, C.3 Provision of Services to Health Center Patients, and C.4 Covered Services to Non-Health Center Patients. Section C.4 reads in part: 

"Homeless Outreach - Health center staff travel to a shelter for homeless persons or a street location where homeless persons congregate, to conduct intake screening to determine those in need of clinic services. Health care services may be provided at the time of the intake activity or during subsequent clinic staff visits to that location."

We cannot provide general assurance of FTCA coverage in all situations, as such determinations are “fact specific.” If you have questions on how your health center’s specific street medicine model would be documented in your health center’s scope of project or covered by FTCA, please reach out to BPHC using the BPHC Contact Form. 

(Added: 12/23/2024)
 

This question relates to Serving Justice-Involved Individuals Reentering the Community and PIN 2024-05 (PDF - 482 KB).

Review the criteria in Section VI of PIN 2024-05 (PDF - 482 KB). If your health center meets these criteria, you may provide any of the services listed in Section VII of the PIN. 

You must have exclusive control and authority over the services provided to justice-involved individuals reentering the community (JI-R individuals). If facts (for example, language in your written agreement with the carceral authority) indicate your providers are acting on behalf of a third party and not your health center, we will consider these services and the carceral setting outside your health center’s scope of project. 

All services your health center provides must support transitions in care during the 90-calendar-day period prior to a JI-R individual’s scheduled or expected release. For JI-R individuals without an official expected or scheduled release date, this is for a period no longer than 90 calendar days.

(Added: 12/4/2024)
 

This question relates to Serving Justice-Involved Individuals Reentering the Community and PIN 2024-05 (PDF - 482 KB).

Your health center can provide transitional care services (consistent with those in Section VII of PIN 2024-05 (PDF - 482 KB)) in carceral settings including prisons, jails, juvenile justice facilities, or other carceral facilities operated by or on behalf of a state or local government.

You may not provide in-scope health center services to JI-R individuals in the care and custody of the federal government, even if they are in the same carceral setting as those in the care and custody of a state and/or local government.

(Added: 12/4/2024)

This question relates to Serving Justice-Involved Individuals Reentering the Community and PIN 2024-05 (PDF - 482 KB).

Yes. You must have a signed memorandum of agreement or understanding (MOA/MOU) with the carceral authority that operates the carceral setting where you will provide transitional care services. A carceral authority is the local or state government that is responsible for the care and custody of the JI-R individual.

(Added: 12/4/2024)
 

This question relates to Serving Justice-Involved Individuals Reentering the Community and PIN 2024-05 (PDF - 482 KB).

You can add transitional care in carceral setting (TCCS) locations through the Electronic Handbooks (EHBs) Scope Module. You should first review the criteria in PIN 2024-05 (PDF - 482 KB)  to ensure your change in scope request meets all PIN requirements. 

You will submit requests to add TCCS locations through a Change in Scope (CIS) Scope Adjustment request for an "Administrative-Only Site." Under “Scope Adjustment Request: Make minor adjustments or modifications to scope of project,” select “Add an Admin Only Site.” You cannot add TCCS locations as "Service Sites."

If we approve the CIS request for the TCCS location, we will not issue a notice of award (NoA) or notice of look-alike designation (NLD). However, the TCCS location will appear on your Form 5B in EHBs as an Administrative-Only Site which will serve as documentation that the location is within your scope of project. TCCS locations will not appear in Find a Health Center.

All services you provide at these TCCS locations must be within the list of allowable transitional care services in Section VII of PIN 2024-05 (PDF - 482 KB). These services must be within your approved scope of project (as documented on Form 5A: Services Provided) and, as with all in-scope services, you must make those services available to all residents of your service area. 

Use the following resources to prepare your health center’s CIS request:

• Guidance for Completing a Change in Scope Request to Add Transitional Care in Carceral Setting to Your Scope of Project (PDF - 248 KB)
• EHBs Quick Reference Guide for Transitional Care in Carceral Setting CIS Requests (PDF - 1 MB)

(Added: 12/20/2024)

This question relates to PAL 2026-04 (PDF - 309 KB).

The CIS module will be unavailable from October 20 through November 19, 2026, while HRSA updates the system. The CIS module will reopen November 20, 2026.

HRSA will close:

• New CIS requests not submitted to HRSA by 11:59 p.m. ET on October 19.
• CIS requests returned for clarifying information (Change Requests) not resubmitted to HRSA by 11:59 p.m. ET on October 24.

If a CIS request is closed, you will need to create and submit a new CIS request when the CIS module reopens on November 20.

(Added: 8/14/2026)

This question relates to PAL 2026-04 (PDF - 309 KB).

If you need to submit a CIS request due to a declared emergency between October 20 and November 19, 2026, you should use the BPHC Contact Form and e-mail your Project Officer to notify and submit a temporary service site request. Project Officers will assist you with requests to add temporary emergency sites.

(Added: 8/14/2026)

This question relates to PAL 2026-04 (PDF - 309 KB).

On November 20, 2026, HRSA will administratively move existing scope of project information into the updated formats for Form 5A: Services Provided and Form 5B: Sites. No action is needed by health centers for this data migration.

(Added: 8/14/2026)

This question relates to PAL 2026-04 (PDF - 309 KB).

If you have an application for funding or look-alike designation in progress and have not submitted it to HRSA by 5:00 p.m. ET on November 19, 2026, the system will automatically clear any data you entered into scope-related forms (Form 5A: Services Provided, Form 5B: Service Sites, and Form 5C: Other Activities/Locations). You will need to complete these forms again after the system opens on November 20. This does not apply to applications with read-only scope-related forms.

(Added: 8/14/2026)

This question relates to PAL 2026-04 (PDF - 309 KB).

The CIS module will be unavailable from October 20 through November 19, 2026, while HRSA updates the system. The CIS module will reopen on November 20, 2026.

HRSA will close:

• New CIS requests not submitted to HRSA by 11:59 p.m. ET on October 19.
• CIS requests returned for clarifying information (Change Requests) not resubmitted to HRSA by 11:59 p.m. ET on October 24.

If you submit your health center’s CIS request before October 20, make sure the request is accurate and complete to minimize delays or requests for additional information during the review and approval process. If the CIS request is closed, you will need to create and submit a new CIS request when the CIS module reopens on November 20.

Health centers are encouraged to contact their Project Officers as soon as possible if they anticipate submitting a CIS request prior to October 20. If possible, you are encouraged to submit CIS requests after the system reopens with the new improvements, to take advantage of the streamlined process.

(Added: 8/14/2026)