CLIENT ALERT: HRSA Updates Health Center Program Compliance FAQs

By , | Published On: March 23, 2023

On March 8, 2023, the Health Resources and Services Administration (“HRSA”) updated its resource, Health Center Program FAQs, to include new and modified FAQs related to the Health Center Program, with a focus on common questions regarding the Compliance Manual and Site Visit Protocol. Many of these FAQs address programmatic requirements that often result in findings of non-compliance.

New Health Center Program FAQs include, but are not limited to:

  • Do contracts/agreements or referral arrangements for enabling services need to include the same provisions as contracts/agreements or referral arrangements for clinical services?
  • How are transportation services defined, and how would a health center accurately record such services on Form 5A: Services Provided?
  • Can a health center provide communicable disease screening and treatment to individuals who are not established health center patients?
  • If a health center submits a contract/agreement or referral arrangement for a service that is not recorded on Form 5A: Services Provided in Columns II or III, would the health center receive a non-compliance finding?

Upcoming Training Events

To learn more about how to draft and maintain compliant formal referral agreements for in-scope services, and otherwise avoid common Form 5A pitfalls, join FTLF Partner Carrie Riley for her webinar, “Referral Agreements and the Health Center Program,” March 29, 2023 at 1:00 p.m. ET.

For a full chapter-by-chapter review of the Compliance Manual, see our three-day training, “Deciphering the Operational Site Visit: Legal Requirements and Practical Tips for a Successful Compliance Assessment,” taking place May 3-5, 2023.