Summary of HRSA Health Center Program Requirements

Both Federally Qualified Health Centers, which receive Federal funding, and Federally Qualified Health Center Look-Alikes, which do not, must meet a strict set of HRSA health center program requirements. The following list provides a summary of the HRSA health center program requirements.

Need

1. Needs Assessment: Demonstrate and document the needs of the target population, including updating their service area, when appropriate. (Section 330(k)(2) and Section 330(k)(3)(J) of the PHS Act)

2. Medically Underserved Area (MUA)/Medically Underserved Population (MUP) Designation: Serve, in whole or in part, a designated MUA/MUP. (Section 330(a) of the PHS Act) (Requested, not required for HCH, PHPC, or MHC applicants)

Services

3. Required and Additional Services: Provide all required primary, preventive, enabling health services and additional health services as appropriate and necessary, either directly or through established written arrangements and referrals per program requirements. (Section 330(a) of the PHS Act) Note: Applicants requesting funding to serve homeless individuals and their families must provide substance abuse services among their required services. (Section 330(h)(2) of the PHS Act)

4. Staffing Requirement: Maintain a core staff as necessary to carry out all required primary, preventive, enabling health services and additional health services as appropriate and necessary, either directly or through established arrangements and referrals. (Section 330(a)(1) and (b)(1), (2) of the PHS Act)

5. Accessible Hours of Operation/Locations: Provide services at times and locations that assure accessibility and meet the needs of the population to be served. (Section 330(k)(3)(A) of the PHS Act)

6. After Hours Coverage: Provide professional coverage during hours when the center is closed. (Section 330(k)(3)(A) of the PHS Act)

7. Hospital Admitting Privileges and Continuum of Care: Physicians have admitting privileges at one or more referral hospitals, or other such arrangement to ensure continuity of care. In cases where hospital arrangements (including admitting privileges and membership) are not possible, applicant must firmly establish arrangements for hospitalization, discharge planning, and patient tracking. (Section 330(k)(3)(L) of the PHS Act)

8. Sliding Fee Discounts: A system in place to determine eligibility for patient discounts adjusted on the basis of the patient’s ability to pay. This system must provide a full discount to individuals and families with annual incomes at or below the poverty guidelines (only nominal fees may be charged) and for those with incomes between 100 percent and 200 percent of poverty, fees must be charged in accordance with a sliding discount policy based on family size and income. No discounts may be provided to patients with incomes over 200 percent of the Federal poverty level. (Section 330(k)(3)(G) of the PHS Act and 42 CFR Part 51c.303(f))

9. Quality Improvement/Assurance Plan: Ongoing Quality Improvement/Quality Assurance (QI/QA) program that includes clinical services and management and maintains the confidentiality of patient records; the QI/QA program must include:

  • A focus of responsibility to support the quality improvement/assurance program and the provision of high quality patient care;
  • Periodic assessment of the appropriateness of the utilization of services and the quality of services provided or proposed to be provided to individuals served by the applicant; and
  • Such assessments shall: be conducted by physicians or by other licensed health professionals under the supervision of physicians; be based on the systematic collection and evaluation of patient records; and identify and document the necessity for change in the provision of services by the applicant and result in the institution of such change, where indicated. (Section 330(k)(3)(C) of the PHS Act and 42 CFR 51c.303(c)(1-2))

Management and Finance

10. Collaborative Relationships: Establish and maintain collaborative relationships with other health care providers, including other health centers, in the service area of the center. Interested section 330 applicants must secure a letter of support from the existing health center(s) in the service area or provides an explanation for why such a letter of support cannot be obtained. (Section 330(k)(3)(B) of the PHS Act)

11. Affiliation Agreements: Appropriate oversight and authority over all contracted services. Section 330(k)(3)(I)(ii) and 42 CFR Part 51c.303(n), (t))

12. Key Management Staff: Maintain a fully staffed health center management team as appropriate for the size and needs of the center. Prior review of final candidates for Project Director/Executive Director/CEO position is required. (Section 330(k)(3)(H)(ii) of the PHS Act and 45 CFR Part 74.25 (c)(2), (3))

13. Financial Management and Control Policies: Accounting and internal control systems are appropriate to the size and complexity of the organization reflecting Generally Accepted Accounting Principles (GAAP) and separates functions appropriate to organizational size to safeguard assets. Assures that an annual independent financial audit is performed in accordance with Federal audit requirements, addressing all reportable/material weaknesses in the Audit Report. (Section 330(k)(3)(D), Section 330(q) of the PHS Act and 45 CFR Part 74.21)

14. Program Data Reporting Systems: Systems which accurately collect and organize data for program reporting and which support management decision making. (Section 330(k)(3)(I)(ii) of the PHS Act)

15. Billing and Collections: Systems in place to maximize collections and reimbursement for costs related to providing health services, including written billing, credit, and collection policies and procedures. (Section 330(k)(3)(F) and (G) of the PHS Act)

16. Budget: Reflects the costs of operations, expenses, and revenues (including the Federal grant) necessary to accomplish the service delivery plan. (Section 330(k)(3)(D), Section 330(k)(3)(I)(i), and 45 CFR Part 74.25)

17. Service Level: Maintain funded scope of project (i.e., projected number of patients to be served, including any increases based on recent New Access Point/Expanded Medical Capacity awards). (45 CFR Part 74.25)

Governance

18. Board Authority: Governing board maintains appropriate authority to oversee the operations of the center, including:

  • holding monthly meetings (May be waived for eligible applicants. See Form 6- B),
  • approval of the health center’s grant application and budget,
  • selection/dismissal and performance evaluation of the health center CEO,
  • selection of services to be provided and the health center’s hours of operations,
  • establishment of general policies for the health center. Note: Some fiscal and personnel policies may be retained in the case of public centers (also referred to as “public entities”). (Section 330(k)(3)(H) of the PHS Act)

19. Conflict of Interest Policy: Bylaws or written corporate board-approved policy include provisions that prohibit conflict of interest or the appearance of conflict of interest by board members, employees, consultants, and those who furnish goods or services to the health center. No board member shall be an employee of the health center or an immediate family member of an employee. The Chief Executive Officer may serve only as an ex-officio member of the board. (45 CFR Part 74.42 and 42 CFR Part 51c.304(b), when applicable)

20. Board Composition (May be waived for eligible section 330 applicants. See Form 6- B): Governing board must be composed of individuals, a majority of whom are being served by the center and, who as a group, represent the individuals being served by the center. Interested section 330 applicants that receive/request targeted funding to serve migrant and seasonal farmworkers, individuals experiencing homelessness, and/or residents of public housing, must have appropriate representation on the board from these populations. (Section 330(k)(3)(H) of the PHS Act)

21. Waiver of Board Requirements (Applicants requesting targeted funding under sections 330(g), 330 (h), and/or 330(i) but not requesting 330(e) funds): Upon a showing of good cause the Secretary shall waive, for the length of the project period, all or part of the requirements of this subparagraph in the case of a health center that receives a grant pursuant to subsection (g), (h), (i), or (p). Such eligible applicants may request a waiver of the Board Composition and/or Monthly Meeting requirement(s). (Section 330(k)(3)(H) of the PHS Act)

22. Board Size (for CHC and MHC): Governing board has at least 9 but no more than 25 members, as appropriate for the complexity of the organization. (42 CFR Part 51c.304)

23. Board Expertise (for CHC and MHC ): Remaining members of the board shall be representative of the community in which the center’s catchment area is located and shall be selected for their expertise in community affairs, local government, finance and banking, legal affairs, trade unions, and other commercial and industrial concerns, or social service agencies within the community. (42 CFR Part 51c.304)

24. Non-Consumer Board Member Income (for CHC and MHC ): No more than one-half (50%) of the non-consumer board members may derive more than 10 percent of their annual income from the health care industry. (42 CFR Part 51c.304)

 

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