Considerations for Health Center Scope of Project and the COVID-19 Public Health Emergency

HRSA’s Policy Information Notice (PIN) 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB) is the foundational policy for a health center’s scope of project. In addition, during this public health emergency, HRSA has developed further guidance, including:

Scope of Project and COVID-19: The following questions and corresponding criteria serve as a guide to assist you in thinking through scope considerations for health center services and activities during the COVID-19 public health emergency. For HRSA to consider a service or activity to be within your health center scope of project during the COVID-19 public health emergency, you must meet all the criteria for each question.

Please note that this resource does not account for all potential situations. In addition, certain changes for your scope of project require HRSA prior approval. See HRSA Health Center Program Scope of Project for more information and contact your Project Officer or Health Center Program Support HRSA BPHC exit disclaimer for additional information or assistance.

Are services/activities performed on behalf of the health center?

  • Health center providers (i.e., employees, contractors, or volunteers) working under the direction of the health center deliver services;
  • Health center provider time is compensated by the health center (using grant or non-grant funds, including but not limited to H80, H8C or H8D funds);
  • Health center providers deliver services or carry out activities in accordance with the health center’s policies and procedures;
  • The governing board retains control and authority over the activities/provision of any services, regardless of whether the activities take place at a health center site or at another location within the community;
  • The health center establishes and/or maintains a patient record for all individuals served; and
  • The health center bills for the services, as applicable.

Are you providing in-scope services?

  • The health center accurately reflects services related to COVID-19 on Form 5A: Services Provided; COVID-19 screening, triage, testing, diagnosis, treatment, and vaccination are elements of general primary care, diagnostic laboratory services, and immunizations, as reflected on Form 5A; and
  • The health center conducts any notification to identified contacts of patients who test positive for COVID-19 in coordination with federal, state, and local public health activities, consistent with public health guidance and applicable law, including laws relating to communicable disease reporting and privacy.

Where are you providing in-scope services?

  • Established health center service sites. Sites already within the HRSA-approved scope of project (i.e., documented on Form 5B: Service Sites);
  • Modular units, tents, trailers at in-scope sites. If the health center provides services via new modular units, tents, or trailers, they are located on the grounds of established health center sites already within the HRSA-approved scope of project (i.e., documented on Form 5B: Service Sites);
  • Mobile vans. If the health center provides services via mobile vans that travel to locations in the health center’s service area, the mobile vans are associated with established sites within the HRSA-approved scope of project (i.e., documented on Form 5B: Service Sites);
  • Temporary sites. If the health center provides services at temporary sites, those sites meet the criteria for service sites per PIN 2008-01 (PDF - 224 KB) and the sites will be or have been added to Form 5B: Service Sites per PAL 2020-05 (PDF - 184 KB); health centers may convert administrative-only sites into administrative/service sites through HRSA’s streamlined process, as described in PAL 2020-05;
  • Other locations. If the health center provides COVID-19 health-related services, such as screening, triage, testing, diagnosis, treatment, and vaccinations, outside of health center sites, the services are provided in communities served by the health center, and the health center accurately reflects these activities on Form 5C: Other Activities/Locations (e.g., as immunizations, health fairs, portable clinical care); or
  • Telehealth. If the health center provides services via telehealth, the provider is located at a health center service site or at another location, such as the provider’s home, and the patient receiving in-scope services via telehealth is located at a health center service site or some other location, such as the patient’s home.

Note: If a location where you propose to provide services is not represented by the examples above, contact your Project Officer to determine whether you need to submit a change in scope request to add a temporary site on Form 5B or an activity on Form 5C.

Who will receive in-scope services?

  • Established health center patients; and
  • Other individuals who present for care and are not yet established health center patients.

Will you maintain a record of services provided?

  • The health center establishes or maintains a patient record for all individuals who receive COVID-19 testing, vaccination, treatment, or other services. For example, the health center would maintain a record that identifies the patient, the service(s) provided, the location where services were delivered, the name of the provider(s) delivering the services, and the date and time the services were delivered;
  • The health center notifies patients of all test results and provides other follow-up for services, as applicable; and
  • Health centers that partner with other organizations to conduct community-based immunization programs make arrangements with those organizations, as necessary, to obtain timely documentation of immunizations administered by health center providers.
Date Last Reviewed:  February 2021