Eligibility Requirements For Look-Alike Initial Designation Applicants

Primary Reviewer: Governance/Administrative Expert

Secondary Reviewer: N/A

Authority: Sections 1861(aa)(4)(b) and 1905(l)(2)(B) of the Social Security Act.

Health Center Program Look-Alike (LAL) Initial Designation (ID) Application Instructions & Resources

Document Checklist for Health Center Staff

  • Most recent annual audit and management letters or audited financial statements (if audits are not available).
  • Health center organization chart(s) with names of key management staff.
  • Corporate organization chart(s) (only applicable for public agencies or for organizations with a parent or subsidiary).
  • Agreements with parent corporation, affiliate, subsidiary or other controlling organization (if applicable).
  • Documentation (for example, employment contracts) that demonstrates the organization is not owned, operated, or controlled by another entity.
  • Most recent co-applicant agreement (if applicable).
  • If the applicant has contracts that support the proposed Health Center Program scope of project (i.e., to provide health center services or to acquire other goods and services), provide a complete list of these contracts. Include all active contracts and all contracts that had a period of performance which ended less than 3 years ago. In the list, include all of the following information for each contract:
    • Contractor/contract organization;
    • Brief description of the good(s) or service(s) provided;
    • Period of performance/timeframe (for example, ongoing contractual relationship, specific duration); and
    • Whether the contract constitutes substantive programmatic work1 (i.e., contracting with a single entity for the majority of health care providers).
  • Contracts for substantive programmatic work.
  • Position description for the Project Director/CEO.
  • Patient Services Utilization Report (for example, from the Electronic Health Records (EHR)) from within the past 6 months. Data should include patient demographics, type of services, and how the service was provided (Column I, II, or III).
  • Health center selection of three to five health center patient records2 (for example, using live navigation of the EHR, screenshots from the EHR, or actual records if the records are not electronic/EHR records) that document the provision of various required and additional health services.
  • Sample of up to three Medicare or Medicaid claims or other billing documents that demonstrate under what organizational entity or unit billing is conducted.
  • Project Director/CEO employment agreement.

Eligibility Requirements

  1. Is this a Look-Alike Initial Designation Site Visit?

    Response is either: Yes or No

    NOTE: If “No” was selected, NONE of the questions in this Look-Alike Initial Designation section are applicable.

​Select each section below for the corresponding text of the eligibity requirement, site visit team methodology, and site visit finding questions.

An organization applying for look-alike designation must demonstrate to HRSA that it is currently delivering primary health care services to patients within the proposed service area.

Site Visit Team Methodology

  • Confirm that applicant is currently delivering primary care services through the tour of service delivery sites (one or more sites as listed on Form 5B) and the review of patient services utilization report; and
  • Review selection of three to five health center patient records (either using live navigation of the Electronic Health Records (EHR), screenshots from EHR, or actual records if the records are not electronic/EHR records) that document the provision of various required and additional health services.

Site Visit Findings

  1. Is the applicant CURRENTLY DELIVERING PRIMARY HEALTH CARE SERVICES to patients within the proposed service area?

    Response is either: Yes or No

    If No, an explanation is required.

  2. Does the health center have at least one permanent service delivery site that:
    • Provides comprehensive primary medical care as the site’s main purpose?

      Response is either: Yes or No

    • Operates for a minimum of 40 hours per week (with the exception of a health center serving only migratory and seasonal agricultural workers, for which the health center may have a full-time seasonal rather than permanent site)?

      Response is: Yes, No, or Not Applicable

    Notes:

    • A permanent site is a fixed location that operates year-round.
    • Only select “Not Applicable” if the health center is applying for designation to serve only migratory and seasonal agricultural workers.

    If No was selected for any of the above, an explanation is required.

  3. IF NOT APPLICABLE: Does the health center serving only migratory and seasonal agricultural workers have at least one full-time seasonal service delivery site?

    Response is either: Yes or No

    If No was selected, an explanation is required.

An organization applying for look-alike designation must demonstrate to HRSA that it is not owned, controlled, or operated by another entity. Specifically, the organization applying for look-alike designation:

  • Owns and controls the organization’s assets and liabilities (for example, the organization does not have a sole corporate member, is not a subsidiary of another organization), and as such will be able to ensure that the benefits that accrue through look-alike designation as a Federally Qualified Health Center (FQHC) are distributed to the Health Center Program project (for example, FQHC payment rates, 340B Drug Pricing); and
  • Operates the Health Center Program project. At a minimum, the look-alike applicant organization demonstrates that it maintains a Project Director/CEO who will carry out independent, day-to-day oversight of health center activities solely on behalf of the applicant organization’s governing board.

Site Visit Team Methodology

  • Review applicant’s current organization chart(s).
  • Review Project Director/CEO position description and employment agreement.
  • Interview Project Director/CEO.
  • Interview CFO/financial staff of the applicant organization and board members (for example, board chair, board treasurer) regarding ownership and operation of the applicant organization.
  • Review most recent annual audit and management letters or audited financial statements of the applicant organization.
  • Review Medicare or Medicaid claims or other billing documents that demonstrate under what organizational entity or unit billing is conducted.
  • Review bylaws of applicant organization, and if applicable, the co-applicant agreement for public agency applicants with a co-applicant governing board.
  • Review complete list of contracts to identify those that support substantive programmatic work.
  • Review contracts for substantive programmatic work (if applicable).
  • Review any documents related to the applicant’s parent company, affiliate, subsidiary or other controlling organization that has a substantial role in the operations of the applicant organization (if applicable).
  • Review any additional documentation (for example, employment contracts) that demonstrates the organization is not owned, operated, or controlled by another entity.
    Interview key management or other health center staff involved in procurement or contract oversight.

Site Visit Findings

  1. Was the applicant (i.e., the organization applying for look-alike designation) able to document that the applicant currently OWNS AND CONTROLS THE ORGANIZATION’S ASSETS AND LIABILITIES (for example, the applicant organization does not have a sole corporate member, is not a subsidiary of another organization)?

    Response is either: Yes or No

    If Yes OR No, an explanation is required specifying how the assets and liabilities of the applicant organization are owned and controlled.

  2. Does the applicant have safeguards in place to ensure the benefits that accrue through look-alike designation as a FQHC (for example, FQHC payment rates, 340B Drug Pricing Program eligibility) will only be distributed to the Health Center Program project?

    Response is either: Yes or No

    If No, an explanation is required.

  3. Was the applicant (i.e., the organization applying for look-alike designation) able to document that it operates the Health Center Program project (i.e., the services and activities included in the look-alike application)?

    Response is either: Yes or No

    If No, an explanation is required.

  4. Does the look-alike applicant organization have a Project Director/CEO in place who carries out independent, day-to-day oversight of health center activities (i.e., the services and activities included in the look-alike application), solely on behalf of the governing board of the applicant organization?

    Response is either: Yes or No

    If No, an explanation is required.

  5. Does the health center contract for substantive programmatic work?

    Response is either: Yes or No

    If Yes OR No, an explanation is required. If Yes: Specifically describe how the applicant will still perform a substantive role in the Health Center Program project. If No: Describe whether there are any other contractual or organizational arrangements that prohibit or impede the applicant from performing a substantive role in the Health Center Program project.

 

Footnotes:

  • 1. For the purposes of the Health Center Program, contracting for substantive programmatic work applies to contracting with a single entity for the majority of health care providers. The acquisition of supplies, material, equipment, or general support services is not considered programmatic work. Substantive programmatic work may be further defined within HRSA Notices of Funding Opportunity (NOFOs) and applications.
  • 2. Health centers may choose to provide samples of patient records prior to or during the site visit. If patient records will be provided during the site visit, this should be communicated prior to the site visit to avoid any disruption or delay in the site visit process.