CHC’s are expected to have a scope of project that encompasses the health care services, administrative and clinical sites, service area, target population, and staff that are supported by Section 330 grant funds or a CHC Look-Alike Designation. Having a defined and accurate scope of project is important because:
- Section 330 grant funds can only be used to support “in scope” work, i.e. work that is defined by and in support of the CHC’s scope of project.
- Malpractice coverage through the Federal Tort Claims Act (FTCA) only covers the CHC’s scope of project.
- A CHC participating in the 340B Drug Pricing Program need to ensure any listed service sites are within the approved scope of project.
- HRSA’s position is that CHCs can only seek Medicaid and Medicare reimbursement under the enhanced rates for services provided to eligible Medicaid and Medicare patients at the sites listed in a CHC’s scope of project.
Each CHC must define their scope of project in applications to HRSA through Form 5: Required and Additional Services, Form 5B: Service Sites, and Form 5C: Other Activities/Locations. It is highly recommended that CHCs regularly review these documents to ensure they are up to date and accurate, including that the documents reflect any changes a CHC institutes due to new grant awards or changes in the types of services needed by the CHC patients. If necessary, a CHC must submit a Change in Scope request in order to update the scope of project to reflect any changes that are documented on Forms 5A, 5B and 5C.
HRSA has posted a variety of resources to provide guidance around the scope of project requirements, all of which can be found through the main Scope of Project webpage.
In particular, the following documents should be reviewed in detail to ensure understanding of what the scope of project entails:
Any changes in a CHC’s scope of project must be made at least 60 days before the intended date of implementation through a Change in Scope (CIS) request and are required for:
- Adding a new service or service delivery site
- Terminating an existing service or service delivery site
- Adding a new target population
In order to submit a CIS request, the CHC must document that there is or will be adequate revenue to cover all costs associated with making a change to a CHC’s scope of project. This is because any changes to a CHC’s scope of project must be completed and sustained without additional Section 330 grant funds. As well, there must be record in the board minutes that the CHC’s governing board has reviewed and approved what the proposed change in scope entails, including reviewing any financial analysis done for the CIS request. HRSA has created to resources to assist with financial analysis performed for a CIS request:
A CIS request is submitted via the Electronic Handbook (EHB) and details about the submission process can be found in the CIS EHB User Guide and under the categories of Service Changes, Site Changes, Target Population Changes, Other Activities Change Form on the Scope of Project webpage.
It is possible to submit a CIS request to add a temporary location in response to emergency events. The circumstances when this type of request can be submitted, as well as timeline and submission requirements for the temporary change in scope are outlined in PAL 2014-05: Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events.