Health Center Program Requirements 9 through 16 mandate how Community Health Centers (CHC) are managed, exercise oversight and authority, and maintain accounting/internal control systems.
This chapter supersedes PIN 2014-01: Health Center Program Governance with regard to the CEO reporting to the governing board. In combination with Chapter 12: Contracts and Subawards, it supersedes PIN 1998-24: Amendment to PIN 1997-27 Regarding Affiliation Agreements of Community and Migrant Health Centers.
CHCs are expected to maintain appropriate oversight and authority over all affiliations and contracts, such as contracts with other types of health care organizations that assist CHCs in providing services.
There are Federal procurement grant regulations that CHC staff should be aware of as it relates to contacts and affiliations. These regulations are detailed in the 45 CFR Part 74.41 to 74.48, which are the Department of Health and Human Services’ uniform administrative requirements for awards and sub-awards to institutions of higher education, hospitals, other nonprofit organizations, and commercial organizations.
NACHC has published several resources on the topic of contracts and affiliations:
- The NACHC Corporate Compliance Toolkit, available via subscription through FTLF, includes resources such as checklists for affiliation agreements and sample policy and procedures for procurement.
- Collaborative Arrangements: A Guide for Health Centers and Their Partners was developed through a partnership between NACHC and FTFL and is designed to help CHCs appropriately take part in new collaborative opportunities and ensure compliant partnerships. The manual includes checklists and sample contractual provisions to use. It is only available in hardcopy and costs $199.
- Affiliations Between Health Centers and Other Community-Based Providers, available for free and posted August 2004.
CHCs are expected to establish and maintain collaborative relationships with other health care providers within their service area, including other CHCs. The intent is that these collaborative relationships help ensure CHC patients have access to appropriate health care services. These collaborative relationships can be documented through letters of support, memoranda of agreement/understanding, or other types of documentation of a collaborative relationship.
- CHCs can utilize the tools available in UDS Mapper in order to identify some of the other types of health care providers that operate within their service area.
The Health Resource and Services Administration (HRSA), in partnership with the Office of Federal Assistance Management, published the Tip Sheet for HRSA Grantees: A Guide for Developing Effective Financial Management Practices. This one-page guide briefly outlines baseic practices that shoul dbe followed to ensure that no CHC has to return grant funding due to spending it on unallowable costs.
There are several resources available through the Colorado Department of Health Care Policy and Finance website. To access these resources follow the links below.
NACHC offers a FQHC Billing Manual for a fee. This manual supports CHCs efforts to increase efficiency, and accuracy in the billing and collections process.
CHCs are required to have systems in place to collect and organize data for program reporting. All CHCs are required to prepare a Uniform Data Systems (UDS) report for every calendar year. These reports provide data on staffing, services, and financing for all BPHC funded programs.
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. 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:
- PIN 2008-01: Defining Scope of Project & Policy for Requesting Changes
- PAL 2009-11: New Scope Verification Process
- PAL 2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines
- PIN 2009-02: Specialty Services & Health Centers’ Scope of Project
- PIN 2007-09: Service Area Overlap: Policy & Process
- PAL 2011-07: Sites, Scope of Project, and Capital Projects
- PIN 2009-05: Policy for Special Populations-Only Grantees Requesting a Change in Scope to Add a New Target Population
- Health Center Program Compliance Manual
- Form 5A Services Descriptors
- Form 5A Column Descriptors
- Form 5B Service Site Instructions
- Details about how CHCs are reviewed for compliance with this requirement are found the Site Visit Protocol.
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: Change in Scope Requests to Add Temporary Sites in Response to Emergency Event.