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.