UPDATE: HRSA released newly updated Novel Coronavirus (COVID-19) Frequently Asked Questions on March 24, 2020. To learn more about these updates, read our updated blog here.
On March 17, 2020, HRSA released updated Novel Coronavirus (COVID-19) Frequently Asked Questions.
Highlights include the following:
- Site Visits: BPHC is postponing all planned site visits until a later date to be determined.
- Supplies: If a health center’s regular distributors are unable to fulfill orders for critical medical supplies such as personal protective equipment, the first step is to contact the local and/or state public health department for immediate assistance. If the state is unable to provide supplies, state health officials — through the governor or his/her representative — may request federal assistance from HHS.
- New Funding: The Coronavirus Preparedness and Response Supplemental Appropriations Act provides $100 million for health centers to prevent, prepare for, and respond to the COVID-19 national emergency. HRSA is working quickly to develop a spend plan and will expedite the awarding of funds.
- Emergency Preparedness: Health centers are expected to plan for the continued provision of ongoing preventive and primary care to their patients, consistent with the Emergency Preparedness Final Rule. Specifically, health centers must follow the emergency plans they have developed for their facilities and implement their emergency preparedness communication plan based on their CMS-required annual risk assessments and trainings. Health centers must also coordinate with state and local health departments as part of health centers’ emergency management planning, preparedness, mitigation, and response efforts.
- FTCA: In light of the declaration of a public health emergency, health centers may set up “temporary sites (that) are within the health center’s service area or neighboring counties, parishes, or other political subdivisions adjacent to the health center’s service area” (for in-scope services) with notification made to BPHC within 15 days. Please see PAL 2014-05 for full details and requirements “to ensure that the emergency response at temporary locations is considered part of the center’s scope of project.” For purposes of FTCA coverage, patients served by covered individuals at temporary locations included in the covered entity’s scope of project are considered the covered entity’s patients.
- Reduced Availability of In-Scope Services: HRSA recognizes that during declared emergencies health centers may face staffing shortages and/or facility capacity limitations and may need to prioritize appointments and staffing to address the most urgent needs of patients. No change in scope is necessary if a health center is changing the level or intensity of certain services within the scope of project. If a health center permanently removes a service from its scope of project, a change in scope request to delete the service will need to be submitted for HRSA approval.
- Screenings/Triage: Health centers may provide screenings or triage, including initial consultations to health center patients or to individuals who may become a patient of the health center. This is considered part of general primary care as it is reflected on Form 5A. These activities may be conducted outside of a health center site but must occur within the health center’s service area. This could include screening or triage of patients in their vehicles, on the street to individuals experiencing homelessness, or at a patient’s home as part of Portable Clinical Care or Home Visits, as applicable.
- Telehealth and Home Visits: Health centers may use telehealth to provide services to a patient at a location that is not an in-scope service site as long as: 1) the service being provided via telehealth is within the health center’s approved scope of project (recorded on Form 5A); 2) the clinician delivering the service is a health center provider; and 3) the individual receiving the service is a health center patient. Review PAL 2020-01: Telehealth and Health Center Scope of Project for more information. HRSA strongly encourages health centers that provide, or are planning to provide, health services via telehealth to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Health Center Program requirements; Federal, State, and local requirements; and applicable standards of practice.
- Telehealth and New Patients: Health center providers may provide triage services, including initial consultation, as part of primary care to patients or to individuals that intend to become a patient of the health center. These triage services may be conducted by health center providers either in person or by telehealth, consistent with applicable standards of practice. Review PAL 2020-01: Telehealth and Health Center Scope of Project for more information.
- Changes in Scope: HRSA approval is not required for the provision of in-scope health center services at the following locations already within the approved scope of project:
- An approved health center service site (on Form 5B), including the addition of any modular units or trailers on the grounds of the 5B site;
- Mobile units (on Form 5B), including driving mobile units to additional locations in the health center’s service area;
- Home visits (on Form 5C) to health center patients, including visiting health center patients in assisted living facilities and nursing homes;
- Portable clinical care (on Form 5C), where health center staff conduct clinical care outside of health center sites (for example, conducting screenings and consultations in a parking lot, on the street to individuals experiencing homelessness).
This list of locations is not exhaustive. Health centers should review their scope of project documentation in the EHBs to ensure that Form 5B and Form 5C are up to date.
- Temporary Sites: HRSA considers all health centers impacted and “eligible” to submit change in scope requests to add temporary sites due to an emergency, if necessary. HRSA approval is required anytime a health center will add a temporary site(s) in response to emergency events when the location would meet the service site definition per PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes. The information needed for this request must be submitted as soon as practicable but no later than 15 days after initiating emergency response activities. See PAL 2014-05.
If you have any questions about this update or other matters, please contact Carrie Bill Riley or call (202) 466-8960.