Health Center Program Compliance Frequently Asked Questions (FAQ)
Can’t find your answer here? Please submit your question through the BPHC Contact Form and select the appropriate issue type, or call Health Center Program Support at 1-877-464-4772.
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.
Scope of project
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:
- You provide services documented on your Form 5A: Services Provided;
- Your health center providers (employees, volunteers, or contractors) deliver the services; and
- 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 - 224 KB) 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)