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Maintaining an Accurate Scope of Project

The accuracy of a health center's scope of project is important because it defines what activities the approved health center program budget can support. Additionally, other federal programs use a health center’s scope of project to make decisions about program eligibility.

Eligibility for other federal programs

Maintaining an accurate scope of project is important when participating in other federal programs. To take part in these programs, a health center must have documentation that the related activities are in the approved scope of project. However, this does not guarantee approval for these benefits. Each of these programs has an application process and a comprehensive set of requirements.

Medicare enrollment for new FQHC sites

Health centers need to inform Medicare when adding new FQHC sites to scope by using the CMS electronic Provider Enrollment, Chain, and Ownership System (PECOS) or submitting a new Medicare Enrollment Application Form 855A (PDF - 794 KB) to their Medicare Administrative Contractor. This is required to enroll any new service site that is approved by HRSA through the change in scope (CIS) process or through a funded application. HRSA encourages health centers to enroll new sites through PECOS because it streamlines the process. View a step-by-step demo video on how to use the PECOS.

When enrolling a new site, health centers must provide the Notice of Award (NoA) or Notice of Look-alike Designation (NLD) that documents approval for the new site and must complete the initial enrollment process with CMS. For more information, see CMS’ Become a Medicare Provider or Supplier website.  

In addition, many state Medicaid programs require new sites to enroll individually and bill for services using a site-specific billing number. For more information, health centers should contact their Primary Care Association or State Medicaid Agency. 

Medicare revalidation for current FQHC sites

CMS requires each health center site enrolled in Medicare (i.e., each FQHC site) to revalidate its enrollment information every five years. CMS also has the right to request more frequent revalidations.  

You can look up the revalidation due dates for your sites in CMS' Medicare Revalidation List tool. Health centers will receive notice from CMS for each FQHC site six months in advance of the revalidation due date. Three months before, their Medicare Administrative Contractor will also reach out by email or mail. If you need to revalidate a site, HRSA recommends using CMS’ online PECOS system, which streamlines the revalidation process. View a step-by-step demo video on how to use the PECOS system.

You must provide the following supporting documentation: 

  • The service site’s NoA or NLD.
  • If the NoA or NLD are not available, provide a copy of the health center’s Form 5B: Service Sites list, downloaded from HRSA’s Electronic Handbooks. Form 5B must include the physical address of the site, and that address must match what is on the CMS revalidation application. 

Use the BPHC Contact Form for questions or concerns about the accuracy of your Form 5B: Service Sites.

Federal Tort Claims Act (FTCA) 

Health centers deemed under the FTCA program can review the FTCA Health Center Policy Manual (PDF - 406 KB). Submit FTCA-specific questions through the BPHC Contact Form or call 877-464-4772, option 1, 8 a.m. – 5:30 p.m. ET, Monday – Friday (except federal holidays). 

340B Drug Pricing Program

Health centers that participate in the 340B Drug Pricing Program should be aware that changes to the scope of project, including adding new HRSA-approved service sites, do not automatically update within the 340B Drug Pricing Program’s Database. Health centers should review 340B Drug Pricing Program Registration to confirm if they need to update the 340B Database. 

National Health Service Corps (NHSC)

Health centers that employ NHSC-obligated clinicians should be aware that these clinicians must only work at an NHSC-approved service site or sites within the health center's scope of project. Note that there can be some sites within a health center’s scope of project that are not NHSC-eligible. NHSC auto-approval of a site is not guaranteed, and comprehensive primary care sites seeking auto-approval must submit a site application to determine eligibility and participate in the NHSC as an approved service site. In addition, there may only be one NHSC Scholar and one Students to Service Loan Repayment Program (S2S LRP) participant per yearly placement cycle.

Review the Eligibility Requirements and Qualification Factors section of the NHSC Site Reference Guide (PDF - 643 KB) for information on eligible and non-eligible NHSC sites. NHSC sites and participants can contact the NHSC through the Customer Service Portal or through the Customer Care Center by calling 1-800-221-9393. Find additional NHSC information at National Health Service Corps.


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