Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions

Last Reviewed: April 7, 2020

HRSA recognizes the essential work being performed by health centers during the COVID-19 pandemic, both in providing testing and care for those directly affected by the virus, while also continuing to provide quality primary health care services for the nation’s underserved. We are updating this page regularly as information becomes available.

Information on the outbreak is available from the Centers for Disease Control and Prevention (CDC).

The answers on this page are organized into the following categories:

Funding and Other Resources

How was the amount of COVID-19 funding determined for each health center? (Added: 3/24/2020)

On Tuesday, March 24, HRSA announced the release of $100 million in fiscal year 2020 COVID-19 funding provided by the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (PDF - 217 KB). HRSA used the following distribution formula:

  • Base value of $50,464, plus
  • $0.50 per patient reported in the 2018 Uniform Data System (UDS), plus
  • $2.50 per uninsured patient reported in the 2018 UDS.

The awards range from approximately $50,000 to more than $300,000, with an average of approximately $70,000 per health center.

Do health centers need to apply for the COVID-19 funding? (Added: 3/24/2020)

To expedite distribution of this critical funding, HRSA plans to make funds immediately available and then collect budget and activities/costs to be supported by the funding.

Why was the COVID-19 funding issued through a separate grant? (Added: 3/24/2020)

To support tracking of Coronavirus Preparedness and Response spending across different parts of the government, COVID-19 awards were issued separately from a health center’s operational (H80) grant award with the activity code H8C. Health centers will need to separately track and account for their COVID-19 prevention, preparedness, and response-related activities supported through this funding.

What is the period of performance for the use of the COVID-19 funding? (Added: 3/24/2020)

The performance period for this funding is 12 months. Funding is available for immediate use, and pre-award costs are permitted for COVID-19 prevention, preparedness, and response-related expenses dating back to January 20, 2020. Health centers have flexibility to use COVID-19 funds as circumstances and needs evolve.

Are Health Center Program look-alikes eligible to receive supplemental funds under the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020? (Updated: 3/30/2020)

No, Health Center Program look-alikes are not eligible for funding under the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (PDF - 217 KB).  Funding under this act is explicitly "for grants under the Health Center Program, as defined by section 330 of the Public Health Service Act." Health Center Program look-alikes are authorized under section 1905(l)(2)(B) of the Social Security Act, a separate authority from section 330 of the Public Health Service Act. Therefore, only Health Center Program awardees are eligible for the first round of COVID-19 funding. HRSA is researching what other coronavirus funds may be available for Health Center Program look-alikes and will provide this information as soon as possible.

Can health centers use COVID-19 Coronavirus Preparedness and Response Supplemental Appropriation Act, 2020 funding (activity code H8C) to pay providers who are not working on COVID-19 related activities? (Added: 3/27/2020)

HRSA recognizes that many health centers need funding to maintain capacity during a time of temporary decreases in revenues resulting from the public health emergency. However, per statute, the COVID-19 awards (PDF - 216 KB) (H8C) are for expenses, including personnel costs, associated with prevention, preparedness and response to COVID-19.

What is the PIN number to access the recently awarded fiscal year 2020 Coronavirus (COVID-19) supplemental funding (new activity code H8C) in the Payment Management System? (Added: 3/30/2020)

Health centers will use the same PIN number they use to access their H80 grant funding through the Payment Management System (PMS). If you experience any issues accessing your H8C grant funding, please contact your PMS accountant, whom you can identify through Find Your PMS Liaison Accountant, and/or contact the assigned Grants Management Specialist identified in your H8C grant Notice of Award.

Is there flexibility regarding the use of equipment or supplies purchased using Health Center Program supplemental funding (e.g., SUD-MH or IBHS) to respond to COVID-19? For example, can our staff use laptops purchased with IBHS funding for telework or tele-psychiatry equipment to support virtual COVID-19 assessments? (Added: 3/24/2020)

Yes. Health center awardees have flexibility in the use of the equipment and supplies purchased with previously awarded supplemental funding to support other in-scope activities at their health center. The requirements for use and disposition of equipment and supplies acquired under the Health Center Program award are governed by the Uniform Administrative Requirements at 45 CFR §75.320 and §75.321.

Will fiscal year (FY) 2021 Service Area Competition (SAC) funding be tied to achievement of patient targets? What about future year SAC funding? (Added: 3/25/2020)

The FY 2021 SAC notice of funding opportunity (NOFO) is still under development. However, HRSA is not planning to make adjustments to service area funding with the FY 2021 SAC. HRSA is exploring how best to align the FY 2022 SAC NOFO with health center performance.

Will HRSA provide waivers for 340B Drug Pricing Program eligibility or compliance requirements? (Added: 3/25/2020)

HRSA understands that many 340B Program stakeholders are concerned about the evolving impact of COVID-19. If a covered entity has a specific concern about 340B eligibility or compliance, they should contact the 340B Prime Vendor via email HRSA BPHC exit disclaimer or at 1-888-340-2787 (Monday-Friday, 9:00 a.m. to 6:00 p.m. ET). For more information, visit the HRSA Office of Pharmacy Affairs COVID-19 Resources webpage.

What impact will COVID-19 have on National Health Service Corps and Nurse Corps participants? (Updated: 3/30/2020)

Please see the National Health Service Corps and Nurse Corps: Coronavirus (COVID-19) Frequently Asked Questions for information about these programs and their response to COVID-19.

Can health centers accelerate the drawdown of their grant funds as a needed response to the COVID-19 emergency? (Added: 3/19/2020)

HRSA is aware that many health centers are experiencing budget challenges associated with COVID-19. Health centers may draw grant funding from Payment Management System (PMS) for expenses in alignment with the health center's financial and operational policies and procedures and the approved grant budget. Acknowledging that this is an unprecedented time, health centers should consider the pace of their spending to ensure they have sufficient funds to avoid any funding shortfall.

As a reminder, advance payments to a Health Center Program awardee must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the awardee in carrying out the purpose of the approved program or project (per the Uniform Administrative Requirements at 45 CFR 75.305).

How can health centers access the Strategic National Stockpile (SNS) to get Personal Protective Equipment (PPE) and additional supplies in response to the coronavirus? (Updated: 3/15/2020)

If a health center's regular distributors are unable to fulfill orders for critical medical supplies such as PPE, the first step is to contact your local and/or state public health department for immediate assistance. If the state is unable to provide supplies, state health officials — through the governor or his/her representative — may request federal assistance from the U.S. Department of Health and Human Services (HHS).

If assistance is approved, the HHS Assistant Secretary for Preparedness and Response will direct deployment of supplies from the SNS to state public health officials. The state is then responsible for distributing the supplies to areas in need. We understand the difficulty of this situation, but the state department of health is your best option for assistance with needed supplies.

Program Oversight and Monitoring

What are HRSA’s expectations for health centers that are unable to demonstrate compliance with one or more requirements due to the COVID-19 public health emergency? (Updated: 3/30/2020)

Health Center Program requirements form the foundation and support the core mission of the health center model of primary care. However, HRSA recognizes that during this public health emergency there may be certain requirements with which a health center cannot demonstrate compliance within the timeframe or specific manner indicated in the Compliance Manual. (For example, staff may be unable to complete basic life support (BLS) re-certification in accordance with the health center’s timeline in its credentialing and privileging procedures, or there could be a delay in the release of the health center’s regular patient satisfaction survey.) HRSA will consider the impact of the COVID-19 public health emergency on the ability of health centers to demonstrate compliance with Health Center Program requirements when making future compliance determinations.

In addition to compliance, each health center is responsible for maintaining its operations, in compliance with all other applicable federal, state, and local laws and regulation beyond HRSA’s authority. This includes but is not limited to those protecting public welfare, the environment, and prohibiting discrimination; state facility and licensing laws; state scope of practice laws; Centers for Medicare & Medicaid Services (CMS) Conditions for Coverage for FQHCs; and state Medicaid requirements. For information on any flexibilities or waivers of other requirements, consult the applicable agency.

Can the health center governing board conduct required monthly meetings virtually instead of in-person? (Added: 3/19/2020)

Yes, as indicated in the Health Center Program Compliance Manual, where geography or other circumstances make monthly, in-person participation in board meetings burdensome, health centers may conduct monthly meetings by telephone or other means of electronic communication where all parties can both listen and speak to all other parties.

Do health centers have to charge nominal charges for services during the COVID-19 public health emergency? (Added: 3/27/2020)

Consistent with current Health Center Program requirements, each health center can determine whether to establish a nominal charge for individuals and families at or below 100% of the Federal Poverty Guidelines. Whether or not to have nominal charges for health center services would be documented in the health center’s board-approved policy(ies) for its sliding fee discount program and would apply uniformly to all patients based only on income and family size. As a reminder, each health center determines:

  • How to document income and family size in health center records.
  • How and with what frequency to re-assess patient eligibility for the sliding fee discount scale.

See more on the Health Center Program Sliding Fee Discount Program requirements.

In addition, consistent with current Health Center Program Billing and Collections requirements, all health centers can utilize their board-approved policies, as well as operating procedures, to waive or reduce fees or payments required by the center due to any patient’s inability to pay.

If my health center has a Service Area Competition/Renewal of Designation or Budget Period Renewal/Annual Certification Progress Report or supplemental reporting coming up will there be a deadline extension? (Added: 3/19/2020)

HRSA is exploring what flexibilities may be available regarding the deadlines.

Will BPHC conduct scheduled Operational Site Visits (OSVs) or other site visits as scheduled? (Updated: 3/26/2020)

Given the importance of health centers in the local, state, and national response efforts, as well as CDC guidance, BPHC will postpone all site visits planned through at least June 30, 2020. This decision is made in consideration of the potential impact to health center operations during the COVID-19 outbreak, BPHC staff and consultants, as well as the need for staff to be available for immediate mission critical assignments.

OSVs and other site visits are an important part of the Health Center Program monitoring and oversight process; therefore, BPHC will reschedule the postposed OSVs and all other site visits as soon as is practical.

Will deadlines for diabetes action plan reporting be extended? (Added: 3/30/2020)

As health centers’ 2020 OSVs are being postponed, diabetes action plans and related reporting are also being postponed for the next quarterly submission. Health centers with active diabetes action plans from 2019 OSVs, or action plans associated with forthcoming 2020 OSVs, should work with their Project Officer to discuss a timeframe for quarterly diabetes action plan reporting that is feasible for the health center.

Will HRSA continue to review and approve new look-alike initial designation applications during the COVID-19 public health emergency? (Added: 3/27/2020)

HRSA continues to welcome look-alike initial designation applications on a rolling basis. For applicants who have already had an onsite compliance review, HRSA will continue using the standard review process, with timeframe accommodations based on the potential impacts of COVID-19. For applicants who have submitted an eligible application and have not had an onsite compliance review, HRSA has postponed all look-alike pre-designation site visits planned through at least June 30, 2020. We will keep all look-alike initial designation applications in an active status until we have an opportunity to make a comprehensive assessment of compliance. During this time, we will offer technical assistance by request and/or in areas where we have frequent onsite compliance visit findings.

Will COVID-19 affect 2019 UDS reporting? What if a health center does not have time to review its 2019 UDS Report because of a high volume of COVID-19 patients? (Added: 3/24/2020)

All 2019 UDS reports were due on February 15, 2020, covering patients served and care provided from January through December 2019. UDS Reviewers will review and quality check from February 15 to March 31. During this time, UDS Reviewers will discuss any relevant data points with health centers to understand the report more completely. Even with the additional demands placed on health center staffing and resources by COVID-19, it is important for health centers to be as responsive as possible to discuss their 2019 UDS reports with their assigned reviewers.

If a health center is concerned that they will not be able to respond to their UDS Reviewer by March 31, they should contact the UDS Support line at 866-837-4357 (866-UDS-HELP) or submit a request via udshelp330@bphcdata.net HRSA BPHC exit disclaimer.

Do screenings for COVID-19 count as a service to be reported in 2020 UDS reports? Do people receiving screenings count as patients? (Added: 3/24/2020)

If the only service an individual receives from the health center is a screening, they are not considered a patient of the health center for the purposes of UDS reporting. If an individual receives additional services with their COVID-19 screening that require independent judgement from a health center provider and the encounter is documented, they may be considered a patient of the health center.

New Will HRSA still require health centers to submit tri-annual reports for fiscal year 2019 Integrated Behavioral Health Services (IBHS) supplemental funding? (Added: 4/7/2020)

No. HRSA will shift from collecting IBHS tri-annual progress reports to monitoring health centers‘ progress at increasing new and/or existing patients receiving substance use disorder and/or mental health services through the submission of 2020 Uniform Data System (UDS) reports.

New What if a health center has not yet reported the required addition of 0.5 FTE to support IBHS activities? Will the health center still receive IBHS year-two funding? (Added: 4/7/2020)

HRSA plans to provide year-two funding to all IBHS recipients this spring. For health centers that reported less than 0.5 FTE in their January 2020 progress report, HRSA is extending the due date of the 0.5 FTE requirement by 12 months to April 30, 2021. Health centers will be required to submit to HRSA a completed IBHS Staffing Impact Form that demonstrates a total of 0.5 FTE in substance use disorder and/or mental health personnel supported by fiscal year 2019 IBHS supplemental funding prior to April 30, 2021. Additional information will be included in the Notice of Award that provides year-two IBHS funding.

Providing Care During Emergencies

What are HRSA's expectations for health centers to address the increased demand for COVID-19 testing? (Added: 3/19/2020)

Health centers that have testing available should prioritize and administer COVID-19 testing consistent with the CDC's latest guidelines. HRSA also encourages health centers to consider walk-up or drive-through testing, as feasible and appropriate.

Health centers that do not currently have COVID-19 testing capability (e.g., access to tests and/or access to adequate personal protective equipment) are encouraged to coordinate with state and local health departments and others as appropriate to facilitate access to testing.

HRSA strongly encourages timely response to any HRSA requests regarding testing and other COVID-19 response needs.

What are health centers required to do to ensure their preparedness for a disease outbreak such as COVID-19? (Added: 3/17/2020)

Health centers are expected to plan for the continued provision of ongoing preventive and primary care to their patients, consistent with the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule. Specifically, health centers must follow the emergency plans they have developed for their facilities and implement their emergency preparedness communication plan based on their CMS-required annual risk assessments and trainings. Health centers must also coordinate with state and local health departments as part of health centers’ emergency management planning, preparedness, mitigation, and response efforts.

New Is there specific guidance on COVID-19 infection control and prevention that health centers should follow? (Added: 4/7/2020)

Health centers should refer to the Centers for Medicare & Medicaid Services Guidance for Infection Control and Prevention of Coronavirus Disease (COVID- 19) in Outpatient Settings (PDF - 171 KB), which provides recommendations to mitigate transmission, including screening, restricting visitors, cleaning and disinfection, and possible closures. Guidance relating to supply scarcity and FDA recommendations are also included. In addition, health centers should monitor the CDC website for information and resources, and should contact their state, local, or territorial health departments or authorities for further guidance on patient safety and infection control and prevention. Health centers may also wish to review the resources ECRI has developed through its COVID-19 Resource Center HRSA BPHC exit disclaimer.

What can health centers do to counter stigma towards certain groups during the COVID-19 outbreak? (Added: 3/27/2020)

Health centers are encouraged to review the CDC guidelines around reducing stigma. They describe actions health centers can take, such as maintaining the privacy and confidentiality of those seeking care, raising awareness of COVID-19 without increasing fear, and sharing accurate information about how the virus spreads.

What should health centers do if there are new COVID-19 public health guidelines that impact the delivery of health center services, e.g., directives to cease non-emergency medical or dental services? (Added: 3/24/2020)

Health centers should follow all applicable public health guidance from federal, state, territorial, and local public health authorities regarding the modification or cessation of the delivery of specific services. The CDC provides updated information regarding the latest clinical or testing guidance for COVID-19 and the Centers for Medicare & Medicaid Services (CMS) provides information regarding Medicare during the COVID-19 public health emergency. In addition, the CDC has oral health resources available.

Should health centers cancel in-person training and technical assistance events and meetings planned in the upcoming months? (Added: 3/24/2020)

HRSA encourages awardees to cancel and/or postpone any in-person engagement events until a later date to be determined. Given the recommendation for social distancing to prevent the spread of the coronavirus, you could consider cancelling, postponing, or rescheduling events or meetings as online events.

New  What obligations do health centers have to pay for sick leave or other benefits for staff during the COVID-19 public health emergency? (Added: 4/7/2020)

Please refer to the Department of Labor for information on common issues employers and employees face when responding to COVID-19 and its effects on wages and hours worked under the Fair Labor Standards Act (FLSA), job-protected leave under the Family and Medical Leave Act (FMLA), and paid sick leave and expanded family and medical leave under the Families First Coronavirus Response Act (FFCRA).

FTCA Requirements

What are the requirements for coverage under the Federal Tort Claims Act (FTCA) in light of the declaration of a national public health emergency? (Added: 3/15/2020)

HHS Secretary Alex Azar issued a declaration of a national public health emergency regarding COVID-19 on January 31. As detailed in PAL 2014-05: Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events (PDF - 200 KB): "HRSA recognizes that during an emergency, health centers are likely to participate in an organized State or local response and provide primary care services at temporary locations." Health centers may set up "temporary sites (that) are within the health center's service area or neighboring counties, parishes, or other political subdivisions adjacent to the health center's service area" (for in-scope services) with notification made to BPHC within 15 days. PAL 2014-05 (PDF – 200 KB) includes full details and requirements “to ensure that the emergency response at temporary locations is considered part of the center's scope of project."

For purposes of FTCA coverage, patients served by covered individuals at temporary locations included in the covered entity's scope of project are considered the covered entity's patients. As such, the covered entity and its providers are covered by FTCA for services provided during the emergency at temporary locations." (See the FTCA Health Center Policy Manual (PDF – 408 KB) Section (I) F: A record of the services provided for each patient should be maintained.)

In addition, please see: Section (I) C.3 of the FTCA Health Center Policy Manual (PDF – 408 KB), Provision of Services to Health Center Patients, which states in part: "To meet the FTCA requirement of providing services to health center patients, a patient-provider relationship must be established. For the purposes of FSHCAA/FTCA coverage, the patient-provider relationship is established when: … Health center triage services are provided by telephone or in person, even when the patient is not yet registered with the covered entity but is intended to be registered."

Please also see the FTCA Health Center Policy Manual (PDF – 408 KB) Section (I) C.4 regarding Coverage in Certain Individual Emergencies.

Additionally, please see PAL 2014-05: Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations (PDF - 200 KB).

For questions about FTCA as it relates to emergency events, please contact Health Center Program Support online HRSA BPHC exit disclaimer or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

Does FTCA coverage extend to telehealth visits with both established patients and non-health center patients? (Updated: 3/27/2020)

When in-scope services are provided through telehealth on behalf of a deemed health center to either established patients or individuals who are not patients of the health center, and all other FTCA Program requirements are met, such services are eligible for liability protections under 42 U.S.C. 233(g)-(n), pursuant to 42 CFR 6.6. Health centers and providers are encouraged to consult with private counsel and/or consider the purchase of private malpractice insurance when undertaking activities that may not be within the health center’s scope of project.

Where can health centers find FTCA guidance related to temporary credentialing and privileging during a declared emergency? (Added: 3/19/2020)

See PAL 2017-07: Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations for guidance (PDF – 288 KB).

Can volunteer providers at a health center receive liability protections under the Health Center FTCA Program? (Updated: 4/7/2020)

Yes, the 21st Century Cures Act (Pub. L. 114-255) extended liability protections to Volunteer Health Professionals (VHPs) for the performance of medical, surgical, dental, and related functions at health centers. For liability protections to apply under section 224(q) of the Public Health Service Act (42 U.S.C. § 233(q)), the volunteer must be a health care professional who is licensed or certified to provide clinical services. This would include Licensed Practical Nurses (LPNs) and Medical Assistants (MAs) who are licensed or certified. Volunteers who are not licensed or certified are not eligible for VHP coverage.

VHPs are not automatically eligible for liability protections under the Health Center FTCA Program. Deemed health centers must apply for such protections for their individual volunteers through a VHP deeming sponsorship application. See Program Assistance Letter (PAL) 2020-03: Calendar Year 2021 Volunteer Health Professional Federal Tort Claims Act (FTCA) Deeming Sponsorship Application Instructions (PDF – 184 KB). The deemed health center must submit to HRSA and receive approval of a VHP deeming sponsorship application for each individual volunteer.

How does a health center submit a VHP deeming sponsorship application? Can a Primary Care Association (PCA) or another entity submit a VHP deeming sponsorship application on behalf of the health center? (Added: 3/19/2020)

Health centers can complete a VHP deeming sponsorship application by accessing the Electronic Handbooks (EHBs) and going to the FTCA application section. The EHBs allow sponsoring health centers to submit multiple VHPs in one application submission. For assistance with this process, please contact Health Center Program Support online HRSA BPHC exit disclaimer or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

Applications for VHP deeming must be submitted by the health center's Authorized Official. However, health centers may seek technical assistance in preparing and submitting such applications from PCAs and other third parties.

Can someone who is employed by one health center volunteer at another health center? (Added: 3/19/2020)

Health centers and their providers are strongly encouraged to exercise caution, as FTCA liability protections may be placed at risk when a provider acts on behalf of more than one entity under circumstances that do not make it clear in what capacity the individual was acting at the time of an event that becomes the subject of a claim or lawsuit. Health centers are reminded that when FTCA matters become the subject of litigation, the U.S. Department of Justice and the federal courts assume significant roles in certifying or determining whether a given activity falls within the scope of employment for purposes of FTCA coverage. Health centers and providers are encouraged to consult with private counsel and/or consider the purchase of private malpractice insurance when individual providers wish to undertake activities on behalf of multiple entities and/or in multiple capacities.

Are free clinic health care practitioners, employees, and individual contractors who provide screenings, triage and other health services to individuals in vehicles within the free clinic’s parking lot (or near the free clinic site) eligible for coverage through HRSA’s Free Clinics FTCA Program? (Added: 3/27/2020)

Yes. In responding to the declared public health emergency, otherwise qualified free clinic health care practitioners, employees, and contractors who have been deemed as Public Health Service employees for purposes of liability protections through the Free Clinics FTCA Program are eligible for such protections for screenings and triage activities relating to the diagnosis and treatment of COVID-19, as well as for other qualifying health services, provided to patients and other individuals seeking such services from the free clinic. These services may be provided at the free clinic or offsite, including at offsite programs or events carried out by the free clinic, which includes providing services on behalf of the free clinic at “drive-up” screening locations in the free clinic parking lot or in other nearby locations.

Free clinic providers located at the free clinic or in such other locations may also utilize telehealth to facilitate the delivery of services to free clinic patients and other individuals. All such contact must be appropriately documented in free clinic patient medical records. In addition, all other Free Clinics FTCA Program requirements remain applicable. For additional information, see Policy Information Notice 2011-02: Free Clinics Federal Tort Claims Act (FTCA) Program Policy Guide (PDF - 381 KB), and the Free Clinics FTCA Program website.

Will HRSA issue a particularized determination for health centers related to COVID-19 activities, similar to the particularized determination that was issued during the H1N1 emergency? (Added: 3/31/2020)

HRSA has issued a particularized determination for health center providers (PDF - 35 KB) that clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of grant-supported health services by individuals who have been deemed as Public Health Service employees through the Health Center FTCA Program and the Health Center VHP FTCA Program. It applies to grant-supported health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the health center, whether in person at the health center, offsite (including at offsite programs or events carried out by the health center), or via telehealth.

Will HRSA issue a particularized determination for free clinics related to COVID-19 activities, similar to the particularized determination that was issued during the H1N1 emergency? (Added: 3/31/2020)

HRSA has issued a particularized determination for free clinic providers (PDF - 34 KB) that clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of qualifying health services by individuals who have been deemed as Public Health Service employees through the Free Clinics FTCA Program. It applies to qualifying health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the free clinic, whether in person at the free clinic, through responsive offsite programs or events carried out by the free clinic, or via telehealth.

Will COVID-19 affect calendar year (CY) 2021 FTCA health center deeming application deadlines? (Updated: 4/2/2020)

Due to the ongoing COVID-19 pandemic, HRSA is extending the CY 2021 deeming application cycle deadline from May 14, 2020, to July 13, 2020. Health centers are strongly encouraged to complete and submit their applications as soon as possible, which will ensure all Notice of Deeming Actions are issued well in advance of December 31, 2020. Health centers that apply early will receive an expedited review.

The EHBs will begin accepting applications on April 13, 2020, with applications due on or before July 13, 2020. Health centers will be able to submit supplemental deeming applications for sponsored VHPs who were not included on their redeeming application beginning on July 31, 2020. For more information, see the HRSA FTCA webpage. If you have additional questions, please contact Health Center Program Support HRSA BPHC exit disclaimer online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

Service Delivery

Do health centers need prior approval from HRSA to temporarily close a site due to COVID-19 (e.g., a site co-located in a senior center, a school-based site where buildings have been closed or a dental site to align with state or local public health guidance, responding to limited provider availability)? (Added: 3/19/2020)

Health centers do not need to request HRSA prior approval via a change in scope in cases where they are temporarily closing a site due to the public health emergency. Health centers should ensure their patients are made aware of closures and where and how to seek care at other service delivery sites as appropriate.

If a health center determines that it will permanently close a site after the public health emergency, it must submit a change in scope for HRSA approval to delete the site.

Can my health center reduce the delivery of some required or additional services (e.g., dental services, physical therapy) during a public health emergency? (Added: 3/17/2020)

HRSA recognizes that during declared emergencies health centers may face staffing shortages and/or facility capacity limitations and may need to prioritize appointments and staffing to address the most urgent needs of patients. No change in scope is necessary if your health center is changing the level or intensity of certain services within the scope of project. If a health center permanently removes a service from its scope of project, a change in scope request to delete the service will need to be submitted for HRSA approval.

Can health centers conduct screening or triage of health center and non-health center patients outside of the health center's service sites? (Added: 3/19/2020)

Yes. Screening or triage of health center patients performed on behalf of the health center are elements of general primary care as reflected on Form 5A: Services Provided. The Health Center Program views providing screenings and triage to any patient — including both established health center patients and to individuals who are not established patients of the health center – at the health center, outside on its grounds, or elsewhere in the community as within the health center's scope of project (see 42 CFR 6.6 (e)(4)(i)(C)). This includes providing such screening and triage to patients in the parking lot of the health center or in other community locations.

New Can health centers decrease or increase the hours of operation at service sites during the public health emergency? (Added: 4/7/2020)

HRSA recognizes that health centers may need to change the hours of operation of their service sites during the declared emergency. No change in scope is necessary if your health center is temporarily increasing or decreasing hours of operation at one or more sites. If a health center permanently changes the hours of operation at one or more sites, they should submit a scope adjustment request for HRSA approval. As with any changes that may have impacts on access to care, health centers should ensure patients are made aware of changes to site hours of operation.

May health centers provide in-scope services through telehealth to individuals who are not current health center patients? (Added: 3/19/2020)

As a result of the Secretary's declaration relating to the current COVID-19 public health emergency, health center providers may deliver in-scope services via telehealth to individuals who have not previously presented for care at a health center site and who are not current patients of the health center for the duration of this public health emergency. This includes triage services, including initial consultations. Telehealth visits are within the scope of project if:

  • The individual 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 physically located at a health center service site or at some other location on behalf of the health center (e.g., provider’s home, emergency operations center).

Health centers should focus services provided by telehealth on serving patients and other individuals located inside their service area or with areas adjacent to the covered entity’s service area. HRSA recognizes that patients outside these areas may seek health center screenings and triage by telehealth. Health centers that continue to maintain services for target populations in their service area and provide occasional in-scope services via telehealth to individuals outside these areas would be providing services within the Health Center Program scope of project for all such activities. Please review PAL 2020-01: Telehealth and Health Center Scope of Project (PDF – 520 KB) for more information.

Can a health center use telehealth to provide services to a patient at a location that is not an in-scope service site? Can this occur if neither the health center provider nor the patient is at an in-scope service site (e.g. both the provider and patient are at their respective homes)? (Updated: 4/7/2020)

From a Health Center Program scope of project policy perspective, using telehealth to provide services to a patient at a location that is not an in-scope service site is allowable if:

  1. The service being provided via telehealth is within the health center's approved scope of project (recorded on Form 5A);
  2. The clinician delivering the service is a health center provider working on behalf of the health center; and
  3. The individual receiving the service is a health center patient.

HRSA strongly encourages health centers that provide, or are planning to provide, health services via telehealth to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Health Center Program requirements; federal, state, and local requirements; and applicable standards of practice. HRSA also encourages health centers to consider the range of issues that would support successful implementation of telehealth. Please review PAL 2020-01: Telehealth and Health Center Scope of Project (PDF – 520 KB) for more information.

For questions about FTCA coverage, please contact Health Center Program Support HRSA BPHC exit disclaimer online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

New Do health centers need to request a change in scope for a provider to deliver in-scope services via telehealth from their home or another site not on Form 5B, assuming all the criteria for doing so (see question above) are met? (Added: 4/7/2020)

Health centers do not need to request a change in scope to deliver in-scope services via telehealth on behalf of the health center from the provider’s home or from another location that is not a Form 5B Service Site. In addition, health centers do not need to have "Home Visits" listed on their Form 5C: Other Activities/ Locations in order to provide in-scope services via telehealth.

For questions about FTCA coverage, please contact Health Center Program Support HRSA BPHC exit disclaimer online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

Are there any new Health Insurance Portability and Accountability Act (HIPAA) flexibilities or considerations for providing telehealth visits using readily available technologies such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype? (Added: 3/25/2020)

The HHS Office for Civil Rights issued a Notification of Enforcement Discretion for telehealth remote communications during the COVID-19 nationwide public health emergency on March 17, 2020, which indicates HHS will not impose penalties for noncompliance with regulatory requirements under HIPAA rules in connection with the good faith provision of telehealth during the COVID-19 emergency. There are also Frequently Asked Questions on telehealth (PDF - 94 KB) available.

Providers, including health centers, now have greater flexibility to provide telehealth using any non-public facing remote communication product that is available to communicate with patients (Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype). Note that according to this notification, Facebook Live, Twitch, and TikTok are not allowable applications. See the notification for additional details.

Can health centers bill Medicare for telehealth services as distant site providers? (Added: 4/3/2020)

During this emergency period, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are now eligible to provide telehealth services to Medicare beneficiaries as distant site providers.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act revises the definition of a distant site in section 1834(m)(2)(A) of the Social Security Act to include FQHCs or RHCs that furnish a telehealth service to an eligible telehealth individual during the COVID-19 public health emergency period. Rural and site limitations are removed, so that telehealth services furnished during the emergency period can be provided regardless of the geographic location of the Medicare beneficiary, including if the patient is at home. Telehealth services include medical outpatient office visits, behavioral health services, and other visits currently eligible under the Medicare telehealth reimbursement policies. In order to be eligible for reimbursement, providers must use telecommunication systems with both audio and video capabilities for two-way, real-time interactive communication.

Note that Medicare reimbursement will continue to be provided to FQHCs that use technology-based services furnished through patient-initiated e-visits via an online patient portal or virtual check-ins with a provider.

Is there current guidance on the reimbursement methodology for distant site telehealth visits under Medicare? (Added: 4/3/2020)

Medicare has not yet provided specific guidance on the payment method for telehealth services furnished by FQHCs as distant sites during the emergency period. The CARES Act does provide that FQHCs will be paid at rates similar to the national average payment rates for comparable telehealth services under the physician fee schedule. Please check with the Centers for Medicare & Medicaid Services for additional guidance and updates on FQHC and RHC reimbursement.

Where can I find resources on state Medicaid coverage for telehealth services furnished by health centers as distant site providers? (Added: 4/3/2020)

States have the discretion to cover telehealth through Medicaid; no federal approval is needed for state Medicaid programs to reimburse for telehealth services in the same manner or at the same rate paid for face-to-face services, visits, or consultations. The Center for Connected Health Policy (a National Telehealth Resource Center) has published a quick reference guide HRSA BPHC exit disclaimer (PDF - 197 KB) that summarizes state telehealth responses to COVID-19, including Medicaid coverage. For additional Medicaid information, please visit the COVID-19 FAQs for State Medicaid and CHIP Agencies (PDF - 261 KB).

New During the COVID-19 public health emergency, can a health center utilize a provider to deliver care that is outside of their routine duties? For example, can the health center have an OB/GYN write orders for adult non-OB/GYN patients? (Added: 4/7/2020)

States regulate the practice of medicine and other health professions as part of their authority to establish laws and regulations to protect the health, safety, and general welfare of their citizens. If your state authorizes health practitioners to provide services outside their usual areas of licensure/certification/practice, this should be documented in the health center’s credentialing files, along with fulfillment of any additional requirements for credentialing and privileging.

Temporary Sites

What is a “temporary site” for the purposes of scope of project? (Added: 3/30/2020)

In response to emergency events, health centers can temporarily add sites (including tents, modular units, or trailers) that are not currently within the scope of project. A health center simply provides key information to their Project Officer by email or phone.

Temporary sites must be locations that meet the definition of a service site in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB) as a location where all of the following conditions are met:

  • Health center encounters are generated by documenting in the patients’ records face-to-face contacts between patients and providers;
  • Providers exercise independent judgment in the provision of services to the patient;
  • Services are provided directly by or on behalf of the grantee, whose governing board retains control and authority over the provision of the services at the location; and
  • Services are provided on a regularly scheduled basis (e.g., daily, weekly, first Thursday of every month). However, there is no minimum number of hours per week that services must be available at an individual site.

HRSA’s streamlined process for adding temporary sites during emergencies is described in PAL 2014-05: Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events (PDF – 200 KB).

Under what circumstances can health center services be delivered at a new location without HRSA approval? (Added: 3/30/2020)

HRSA approval is not required for the provision of in-scope health center services at the following locations if these locations are already within your approved scope of project, i.e., documented on Form 5B or Form 5C, including but not limited to:

  • A health center service site (on Form 5B), including any new modular units, tents, or trailers on the grounds of the 5B site;
  • Mobile units (on Form 5B), including delivering in-scope services via mobile units at additional locations in the health center’s service area;
  • Home visits (on Form 5C) to health center patients, including visiting health center patients in assisted living facilities and nursing homes; or
  • Portable clinical care or health fairs (on Form 5C), where health center staff conduct clinical care or COVID-19 testing outside of health center sites (for example, conducting screenings, testing, or consultations in a parking lot or on the street to individuals experiencing homelessness). These activities may be coordinated with state or local health department or other community providers as long as these services are provided on behalf of the health center.

Which health centers are eligible to add temporary sites based on the COVID-19 public health emergency? (Updated: 3/24/2020)

As a result of the Secretary's declaration relating to the current COVID-19 public health emergency, HRSA considers all health centers impacted and “eligible” to submit change in scope requests to add temporary sites due to an emergency, if necessary.

How and when should health centers submit a change in scope request to add a temporary site due to an emergency? (Added: 3/17/2020)

HRSA approval is required anytime a health center will add a temporary site(s) in response to emergency events when the location would meet the service site definition as defined in Policy Information Notice (PIN) 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF – 28 MB). The information needed for this request must be submitted as soon as practicable but no later than 15 days after initiating emergency response activities. HRSA has a streamlined process outlined in PAL 2014-05 Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events (PDF – 200 KB). 

Quality Improvement

Will COVID-19 affect health centers’ eligibility for Quality Improvement Awards (QIAs), considering the challenges patients may face (e.g., patients may be off their medication because they are in isolation)? (Added: 3/24/2020)

Since HRSA will use 2019 UDS data to make determinations for the fiscal year 2020 QIAs, there is no immediate impact of COVID-19 on determination criteria for these awards. For future QIA determinations, HRSA will examine different options in response to shifts in patient utilization and related quality of care indicators.

Will health centers receive communications from accrediting/recognition bodies regarding changes to any current guidance or impacts to their accreditation/recognition? (Added: 3/24/2020)

The Accreditation Association for Ambulatory Health Care (AAAHC) and The Joint Commission (TJC) will keep health centers apprised of changes to the current guidance and impacts to their accreditation. If TJC is your accrediting body, please contact TJC account executive Brittnay Hull at (630) 792-5216 or bhull@jointcommission.org HRSA BPHC exit disclaimer with specific questions.

If you need additional support or have any concerns with your accreditation and PCMH recognition (TJC, AAAHC, or National Committee for Quality Assurance) please reach out to the HRSA APCMH Initiative HRSA BPHC exit disclaimer and you will receive a response within 24 hours. To make sure you receive the response, please add “BPHCAnswers@hrsa.gov” to your address book.

If AAAHC is your accrediting body, please contact AAAHC’s Mona Sweeny at (847) 324-7487 or msweeney@aaahc.org HRSA BPHC exit disclaimer with specific questions.

Will AAAHC or TJC conduct surveys (scheduled or unscheduled) or technical assistance during this time? (Added: 3/24/2020)

TJC has suspended all Joint Commission surveys, Joint Commission Resources (JCR) consulting, and health center external engagements beginning March 16, 2020, until further notice.

AAAHC has postponed all non-emergency surveys scheduled with a start date of March 18 through May 1. If a survey was already scheduled, an AAAHC representative will contact the health center to confirm the postponement and reschedule the survey.

All JCR technical assistance is on hold until the end of April. JCR will reach out to those health centers scheduled for technical assistance to provide further guidance.

What should health centers do if recognition/accreditation through AAAHC, TJC, or the National Committee for Quality Assurance (NCQA) is due to expire soon and it was dependent on a survey review? (Added: 3/25/2020)

AAAHC, TJC, and NCQA are providing extensions for health centers affected by survey postponements and assessing each health center’s circumstances. HRSA will reach out to AAAHC, TJC, and NCQA on behalf of health centers and request extensions, and will follow up with impacted health centers.

NCQA health centers expiring between March 1 and June 30, 2020 will receive a 60-day extension due to COVID-19. HRSA will be revisiting and providing additional support to health centers with expiration dates beyond June as the situation evolves. Health centers transitioning to the 2017 standards will be contacted by NCQA six months before their expiration date to provide guidance.

If a health center chooses to continue to pursue PCMH recognition at this time and is actively undergoing check-ins, they are able to show evidence from any time in the past year. So even if things are temporarily not done according to policy, the health center may still show the policy was routinely implemented before this time.

Partnerships and Special Populations

What options are available for Primary Care Associations (PCAs) and National Training and Technical Assistance Partners (NTTAPs) if activities are cancelled or postponed? (Added: 3/24/2020)

PCA and NTTAP awardees are encouraged to reach out to their Project Officer to discuss any impact to their approved work plans. Changes to the work plan will be considered on a case-by-case basis. If changes need to be made, your Project Officer will send a Request for Information (RFI) through the EHBs for you to outline and provide a detailed description of any new activities you intend to modify or propose. If changes will require a budget revision, please work with you Project Officer to determine the appropriate steps.

How are HRSA-supported National Cooperative Agreements (NCA) disseminating information to health centers and PCAs on COVID-19? Is there a one-stop shop where grantees can find materials and/or upcoming events on COVID-19? (Added: 3/24/2020)

The National Association of Community Health Centers (NACHC), a HRSA-supported NCA, maintains an online repository with up-to-date training and technical assistance resources produced by federal and non-federal entities. The Health Center Resource Clearinghouse HRSA BPHC exit disclaimer is a centralized hub populated with materials developed by all HRSA-funded NCA entities, national organizations, and government agencies on emerging issues HRSA BPHC exit disclaimer including COVID-19. Health centers, PCAs, and other entities can also visit the Clearinghouse for upcoming events and webinars on COVID-19.

How can health centers contribute to community awareness and education to lessen the severity and impact of a COVID-19 outbreak? (Added: 3/24/2020)

As part of their ongoing health education services, health centers can and should inform and raise awareness among their patients and the community of COVID-19 preventive measures; how to recognize symptoms of COVID-19 infection; and what to do if and when they or a member of their family gets sick. Health centers should provide information in a culturally appropriate manner to accommodate people with limited English proficiency. School-based health centers should participate with school administrations in educating students and parents about COVID-19 and appropriate preventive and treatment measures.

Up-to-date information about COVID-19 symptoms, prevention, and treatment is available from the CDC, including materials in Spanish.

How can PCAs assist in ensuring that states integrate health centers in COVID-19 planning and response and in supporting health centers during the COVID-19 pandemic? (Updated: 3/24/2020)

PCAs can facilitate the sharing of important information with health centers through electronic alerts, can conduct outreach to increase awareness and participation in various regional/state pandemic planning and response activities, and can learn from the health centers what issues they face and what assistance may be needed.

PCAs have established mechanisms to engage with health centers in collecting critical information during and after an emergency situation. In addition, PCAs can work to ensure that health centers are included in COVID-19 response plans by tapping into regional/state pandemic planning and response activities. Many PCAs play active roles in the state as coordinators, managers, and disseminators of real-time information during emergencies.

How can Health Center Controlled Networks (HCCNs) help health centers shift towards increased telehealth services and meet reporting requirements during the COVID-19 pandemic? (Added: 3/27/2020)

HCCNs have established platforms to engage with health centers to collect critical information during and after emergency situations, such as the COVID-19 pandemic. HCCNs can:

  • Facilitate important and timely information sharing with health centers through electronic alerts;
  • Assist health centers considering the expansion of telehealth services;
  • Conduct outreach with health centers in their networks to increase awareness of the benefits of telehealth, and share challenges and lessons learned amongst health centers; and
  • Work to ensure that health centers are integrated in regional and state COVID-19 response plans by coordinating with Primary Care Associations (PCAs) on planning and response activities.

Additionally, HCCNs coordinate with the Office of the National Coordinator for Health Information Technology (ONC), the Centers for Medicare and Medicaid Services (CMS), the Health Information and Technology, Evaluation and Quality (HITEQ) Center, and HRSA’s Federal Office of Rural Health Policy (FORHP) to provide training and technical assistance on hardware and/or software, provider education, workflows, patient education, billing and coding, cybersecurity, remote provider education, and policy interpretation.

How can health centers address the unique needs of special populations, such as migratory and seasonal agricultural workers, residents of public housing, and homeless populations, relative to COVID-19? (Added: 3/24/2020)

Health centers provide comprehensive services to address the major health needs of their target population, as well as supportive and enabling services that promote access and quality of care—such as translation, case management, outreach, patient education, and transportation. These services are even more critical for at-risk, vulnerable populations during emergencies.

Health centers may employ and intensify existing outreach services to ensure that the needs of their target populations are being addressed as appropriate. Mobile vans and temporary locations could be established for education and treatment services. Health centers that serve special populations routinely deliver services in areas where these patients live and/or work.

The National Center for Health in Public Housing, a HRSA-supported National Cooperative Agreement (NCA), provides resources HRSA BPHC exit disclaimer tailored for emergency preparedness planning for residents of public housing, as well as individuals with disabilities and special needs.

The National Health Care for the Homeless Council, a HRSA-supported NCA, is organizing federal and local resources HRSA BPHC exit disclaimer tailored for caring for homeless individuals during emergencies or disasters.

Information Collection

What data reporting is HRSA requesting from health centers during the COVID-19 emergency response? (Added: 3/19/2020)

HRSA is asking health centers to fill out a twice-weekly survey to help track the number of patients who have undergone COVID-19 testing at each health center, along with other critical information about health center operations during the pandemic. Each health center will receive an electronic, easy-to-use survey twice a week on Monday and Thursday afternoons from BPHCanswers@hrsa.gov.  The surveys will reduce the need for other methods of information collection around COVID-19.

If health centers have questions while completing the survey, they should contact Health Center Program Support online HRSA BPHC exit disclaimer and select "Coronavirus Inquiries (COVID-19)" as the issue type – the third option on the “Health Center or EHBs Question” screen. You can also call Health Center Program Support at 877-464-4772, option 2, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays).

What is the reporting period for the survey? (Added: 3/19/2020)

Each survey will include instructions. For the report due Tuesday afternoons, health centers should report on activities from Friday of the previous week through Monday. For the report due Friday afternoons, health centers should report on activities from Tuesday through Thursday. The survey includes questions on activities during the reporting period as well as cumulative.

Who at the health center should complete this survey? (Updated: 3/25/2020)

The survey is sent to the Project Director listed in EHBs, but that person can also forward their unique link to anyone in the organization who can report. If you need to add additional points of contact to the survey, please reach out to Health Center Program Support online HRSA BPHC exit disclaimer  and select "Coronavirus Inquiries (COVID-19)" as the issue type—the third option on the "Health Center or EHBs Question" screen. You can also call at 877-464-4772, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays).

If health centers experience particular challenges due to COVID-19, can they report this information through the survey? (Added: 3/19/2020)

Yes. The survey includes an opportunity to provide additional information, comments, or challenges health centers are experiencing due to COVID-19.

How will HRSA use the information from the survey?

HRSA will use the information collected:

  • To assess health centers' needs throughout the COVID-19 response;
  • To share critical information related to testing, cases, and impacts at health centers; and
  • To better understand training and technical assistance, funding, and other resource needs.

What is the role of Primary Care Associations (PCAs) in the COVID-19 survey? (Added: 3/27/2020)

PCAs are expected to regularly communicate with and encourage health centers in completing the COVID-19 surveys. HRSA will collect and share national and state-level COVID-19 data summary reports with each PCA to support targeted technical assistance to the health centers in each state. In addition, each PCA is will be required to complete a separate, weekly online survey to gather information on state-based COVID-19 related issues, challenges, other surveillance information, and PCA/health center needs. This data collection will be used to support timely, coordinated technical assistance and information sharing.

Date Last Reviewed:  April 2020