Health Center Program Service Area Considerations Request for Information (RFI)

Action: Request for Information: Service Area Considerations

Summary: The Health Resources and Services Administration (HRSA) seeks public input and feedback to inform service area-related policy considerations as described in this Request for Information (RFI) and to solicit additional ideas and suggestions from the public related to these topic areas.

Date: Public feedback is now closed.

FAQs: Service Area Considerations Request for Information Frequently Asked Questions

I. Overview of this RFI

HRSA is responsible for the administration and oversight of the Health Center Program, providing grant funding and technical assistance to a nationwide network of community-based and patient-directed health centers to improve the health of underserved communities and vulnerable populations. From 2001 to 2017, the number of health center patients increased by 164%—from 10.3 million to over 27 million. This growth resulted from the addition of new Health Center Program awardees, which increased from over 770 in 2001 to nearly 1,400 in 2017 and new health center service delivery sites operated by the awardees, which grew from over 3,300 to over 11,000.

The Health Center Program is authorized by section 330 of the Public Health Service Act, 42 U.S.C. § 254b. Under this authority, health centers provide required primary health services and additional health services necessary for the adequate support of primary health services to a population that is medically underserved or to a special medically underserved population by providing such services for all residents of the area served by the center (the “catchment area”). Under Health Center Program regulations at 42 CFR Part 51c, community health centers are required to provide their health services so that they are available and accessible promptly, as appropriate, and in a manner which will assure continuity of service to the residents of the center’s catchment area. The concept of a service or “catchment” area has been part of the Health Center Program since its beginning. Although in general, the service area is the area in which the health center’s patients reside, health centers may use other geographic or demographic characteristics to describe their proposed or existing service area consistent with all Health Center Program requirements, including those relating to delivery of services.

Among other requirements, health centers must also implement a system for maintaining the confidentiality of medical records, have an ongoing quality assurance program, and develop management and control systems in accordance with sound financial management procedures, including an annual audit (except as otherwise authorized).

HRSA supports the addition of new health centers and new health center service delivery sites through New Access Point (NAP) Health Center Program funding, approval of Health Center Program look-alike designation applications, and change in scope (CIS) requests (which are implemented without additional Health Center Program funding).

HRSA recognizes that individual health center requests to add new service delivery sites with or without additional Health Center Program funding may be based upon strategic opportunities to strengthen organizational capacity, enhance business operations, or respond to local community need. In turn, HRSA has the responsibility to ensure that limited Federal grant dollars are used to support health centers whose activities align with the Health Center Program authorizing statute and regulations and to maximize the impact of federal funding.1

II. Solicitation of Feedback

HRSA is seeking input from the public on service area considerations that may inform HRSA decisions regarding Health Center Program expansion through an existing health center’s addition of new service delivery sites. These considerations may be applied differently for health centers that are proposing to expand within their existing service area as opposed to health centers that are proposing to expand beyond their existing service area.

Whenever possible, respondents are asked to respond using objective observations or experience and to cite this evidence within their responses, bearing in mind the applicable standards set forth in law, regulations, and policy. HRSA welcomes feedback on the areas of consideration outlined below, as well as more general feedback or suggestions.

III. Service area expansion/new site approval areas of consideration

1. Unmet Need

Specific suggestions for how HRSA should consider unmet need parameters to inform decisions regarding proposed new health center sites, such as in the table below. Section 330(a)3, (e)(6)4, and 330(k)(2)5 of the Public Health Service (PHS) Act; 42 CFR 51c.305(b) and (f)6

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Penetration of the population below 200% of the Federal Poverty Guidelines (FPG). A to-be-defined threshold (e.g., 50%, 75%, or 90%) for Health Center Program penetration of the population below 200% of the FPG by one or more health centers in the area proposed to be served by the new site.

Section 330(e)(6) of the PHS Act4

42 CFR 51c.305(b)(f) of the PHS Act6

PIN 2007-09: Service Area Overlap Policy and Process

B. Other objective measures of unmet need. A minimum ZIP code-level need score based on a service area needs assessment methodology (SANAM)-based unmet need score (UNS) that utilizes public data sources to quantify unmet need for primary care services that can be applied consistently and transparently to inform all health center expansions.

Section 330(e)(6) of the PHS Act4

Section 330(k)(2) of the PHS Act5

42 CFR 51c.305(b), (f)6

Unmet Need Score Resource Guide (PDF - 561 KB)

C. Special Populations. Specific measures for determining the unmet need of special populations, e.g., whether and if so what types of other local data are available to justify a site to serve the special population. Section 330(e)(6) of the PHS Act4 Section 330(k)(2) of the PHS Act5
42 CFR 51c.305(b)(f)6

2. Proximity

Specific suggestions for how and to what extent HRSA should consider proximity to inform decisions regarding proposed new health center sites, such as in the table below. Section 330(e)(6) of the PHS Act4 42 CFR 51c.305(h)-(i)7

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Minimum distance. A minimum distance that a proposed health center site should be from the nearest site operated by a different health center and what might be considered a reasonable minimum distance (e.g., X miles, X minutes), as well as how those distances should vary according to population density or characteristics of rural areas. 42 CFR 51c.305(h)-(i)7

3. Reasonable boundaries for service area

Specific suggestions for how and to what extent HRSA should consider distance and contiguity parameters for reasonable boundaries for service areas to inform decisions regarding proposed new health center sites, such as in the table below. Section 330(k)(3)(J) of the PHS Act8; Section 330(a)(1) of the PHS Act9; 42 CFR 51c.104(b)(2)10

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Distance. The distance of a proposed new site from the requesting health center’s nearest in-scope site and an appropriate to-be-defined threshold (e.g., more than 40 or 50 miles or more for rural/frontier areas, or 5 or 10 miles or more for urban areas.) Section 330(k)(3)(J) of the PHS Act8
B. Contiguity. The ZIP codes served by the proposed new site are contiguous with the ZIP codes of the health center’s existing service area.

Section 330(k)(3)(J) of the PHS Act8

42 CFR 51c.104(b)(2)10

Health Center Program Compliance Manual Chapter 3: Needs Assessment, Demonstrating Compliance Element (a)11

4. Consultation with other local providers

Specific suggestions for how and to what extent HRSA should evaluate consultation with other local providers, consistent with the statutory requirement, such as in the table below. Section 330(k)(2)(D),(3)(B) of the PHS Act12

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Consultation. Criteria to evaluate that health centers have consulted with other local providers for proposed health center expansions and demonstrated good faith efforts to implement a consultative process (e.g., types of documentation HRSA would use to assess consultative efforts). Section 330(k)(2)(D),(3)(B) of the PHS Act12

5. Demonstrated capacity and performance in existing service area

Specific suggestions for how and to what extent HRSA should consider demonstrated capacity and performance parameters for a health center’s existing service area to inform decisions regarding proposed new health center sites, such as in the table below. Section 330(k)(2) of the PHS Act5; 42 CFR 51c.305(g)13

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Patient targets. Demonstration that a health center is on track for achieving its patient target consistent with previous Service Area Competition and supplemental awards and whether the health center has an overall neutral or positive patient trend. 42 CFR 51c.305(g)13
B. Remaining level of unmet need in the current service area. For health centers proposing to expand their service area, the demonstration that the health center has addressed unmet need within the current service area. Section 330(k)(2) of the PHS Act5
C. Quality of care. Demonstration of clinical performance (e.g., through positive trends and/or a demonstration of a basic level of UDS clinical performance).

Section 330(k)(3)(I)(ii)(III) of the PHS Act14

45 CFR 75.34215

PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes, CIS Review Criteria16

D. Provision of comprehensive services. Demonstration that a health center is directly delivering (Form 5A: Column I) and/or is delivering through formal written contracts/agreements (Form 5A: Column II) a comprehensive set of services, including mental health, substance use disorder, and oral health services. 42 CFR 51c.305(l)17

6. Ensuring Patient Input/Representation

Specific suggestions for how and to what extent HRSA should evaluate patient involvement and patient representation in the development and implementation of health center expansion plans, such as in the table below. Section 330(k)(3)(H)(i)-(ii) of the PHS Act18; 42 CFR 51c.304(b),(d)19

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References2
A. Patient involvement in planning. Demonstration of patient involvement in the development of the application or prior approval requests and other planning activities related to the expansion.

Section 330(k)(3)(H)(ii) of the PHS Act18

42 CFR 51c.304(d)19

Section 330(i)(3) of the PHS Act20

B. Patient board representation. A plan for patient-based board representation, including how the plan addresses representation from the newly-proposed service area in addition to representation based on the health center’s previous service area.

Section 330(k)(3)(H)(i) of the PHS Act18

42 CFR 51c.304(b)19

IV. Submitting Feedback

HRSA is no longer accepting feedback. Information obtained as a result of this RFI may be used by the Government for program planning on a non-attribution basis. Respondents should not include any information that might be considered proprietary or confidential. HRSA is not obligated to respond to or directly address individual feedback.

V. Note to Commenters

This RFI is issued solely for information and planning purposes; it does not constitute a Request for Proposal, applications, proposal abstracts, or quotations. This RFI does not commit the Government to contract for any supplies or services or make a grant or cooperative agreement award or take any other official action. Further, HRSA is not seeking proposals through this RFI and will not accept unsolicited proposals. HRSA is not obligated to summarize or publish a response to feedback received, or to respond to questions about the policy issues raised in this RFI. Responders are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the interested party’s expense. Not responding to this RFI does not preclude participation in any future procurement or program, if conducted. It is the responsibility of the potential responders to monitor this RFI announcement for additional information pertaining to this request.

 


1HRSA also recognizes that health centers may choose to engage in other lines of business, including providing health care outside the scope of the Health Center Program. Such activities may include, for example, contracting to provide services on behalf of hospitals and other entities that provide surgical or inpatient health care.

2HRSA recognizes that other statutory, regulatory, and policy references may be applicable as well.

Date Last Reviewed:  July 2019