Health Center Regulatory Issues

HRSA Completes Analysis of Scope Alignment Validation Submissions and Announces Next Steps

In its Primary Health Care Digest dated November 19, 2014, the Health Resources and Services Administration (HRSA) announced that it had completed its analysis of the Scope Alignment Validation (SAV) submissions and is ready to take the next steps in the process to correct health centers’ scope of project forms (Forms 5A and 5B), consistent with the health center’s SAV submission and related comments. As noted in previous Policy Shop blog entries, this past June and July, HRSA conducted a SAV process – a one-time only opportunity for health centers to ensure that their updated scope forms accurately reflected the current services provided and the sites operated by the health center (and if not, to make limited updates and identify the need for additional changes). To assist health centers in understanding these next steps and in taking any actions required of the center, HRSA published a new document, “Scope Alignment Validation Follow-up Actions,” which describes both key action steps and the associated timelines.

In particular, HRSA will be taking the following actions:

• By November 21, 2014, HRSA will delete from Form 5B sites that were identified by the health center as inactive or as duplicates of other sites already in scope.

• By December 5, 2014, HRSA will add or change the service delivery method for Required Services and delete Additional Services (including Specialty Services) from Form 5A, subject to the changes described below.

• In the coming months, HRSA will be making the following additional changes:
o Correct addresses that did not involve a physical location change.
o Update location types where there was a misunderstanding of the site definition.
NOTE: HRSA has stated that if a health center did not receive a targeted Electronic Handbook notification by November 21 regarding a specific site address or location type correction, the requested correction will not be made through this process; rather, the health center will be required to submit a Change in Scope (CIS) request.

Health centers will be required to address all other changes through the CIS process. These changes include:
• Form 5A: Services: (i) adding Additional Services (including Specialty Services) not currently reflected on Form 5A or adding services to Column I and/or II if currently only provided via Column III; and (ii) making any changes to services that are projected to begin at a future date.
• Form 5B: Service Sites: (i) adding or replacing sites (including physical location change); (ii) changing a site from an administrative-only site to a service delivery site; and (iii) changing data fields that were not SAV-related updates.
• Form 5C: Other Activities (changed via a Monitored CIS request): adding or moving an Other Activity to 5C that was incorrectly listed on Form 5A or 5B.
• Other changes: (i) changes needed in cases where HRSA was unable to determine what a health center was specifically requesting as part of its SAV submission comments; and (ii) changes identified after the SAV submission.

All health centers should review this new guidance document along with their scope forms to determine whether changes were made consistent with their SAV submissions and the guidance (and to identify areas where inconsistencies exist), as well as to determine whether additional actions must be taken by the health center.