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.
Sliding fee discount program
This question relates to Element d. Multiple Sliding Fee Discount Schedules
No, a health center cannot have a different SFDS for telehealth services. However, if the locally prevailing charges or the actual costs for services delivered via telehealth differ from those delivered in-person, a health center may have different charges for those telehealth services on the center's fee schedule. The health center applies the SFDS to the fee schedule.
For example, when the cost of providing a primary health care visit through telehealth is less than an in-person visit, the health center may establish a lower charge for the telehealth primary care visit on the health center's fee schedule. If a health center has a percentage-based SFDS, the health center would apply that SFDS to the charge for the telehealth primary care visit, which would be the same SFDS percentage discount applied to an in-person primary care visit. This would result in a lower charge to the patient for the telehealth primary care visit.
As a reminder, nominal charges are set up to be a flat amount; nominal from the perspective of the patient; and not reflective of the actual cost of the service being provided. Therefore, nominal charges do not change based on the fee schedule.
For more information, refer to the Health Center Program Compliance Manual Chapter 16: Billing and Collections.
(Added: 3/8/2023)
Scope of project
Yes. While the COVID-19 PHE ended on May 11, 2023, the telehealth guidance HRSA issued during the PHE will be in effect until HRSA issues new policy guidance, or until December 31, 2024, whichever comes first.
Your health center may provide in-scope services via telehealth to people who have not received care at your health center before and who are not current patients of the health center. This includes triage services, including initial consultations.
Telehealth visits are within the scope of project if:
- The person receives an in-scope required or additional health service;
- The provider documents the service in a patient medical record consistent with applicable standards of practice; and
- The provider is at a health center service site or at another location on behalf of the health center (for example, the provider’s home or an emergency operations center).
You should focus your health center’s telehealth services on patients and other people located in your health center’s service area or in adjacent areas. HRSA recognizes that patients outside these areas may seek screenings and triage through telehealth. If your health center maintains services for the target populations in your health center’s service area, your health center may occasionally provide in-scope services through telehealth to people outside your health center’s service area or adjacent areas.
Refer to PAL 2020-01: Telehealth and Health Center Scope of Project (PDF - 176 KB) for more information.
Be aware that the telehealth reimbursement requirements of third-party payors, including Medicare, may be different from HRSA’s Health Center Program requirements.
(Updated: 10/24/2023)