Health Center Regulatory Issues

HRSA Issues New Program Assistance Letter as Part of New Scope Alignment Process

On May 13, 2014, HRSA issued Program Assistance Letter (PAL) # 2014-06: Documenting Scope of Project in Updated Forms 5A and 5B, in which HRSA described updates to the Scope of Project forms for services and sites (Form 5A and Form 5B, respectively), and posted on its website some additional resource materials that provide further explanation and a preview of each new form. The new guidance is the first step in an overall “scope alignment” process that includes:

  • The updated forms and accompanying resource materials;
  • Migration of each health center’s existing data from the previous forms to the new ones; and
  • One-time only opportunity for health centers to validate the migrated data and to certify the accuracy of services and sites listed as “in-scope” based on the new definitions and resources (the “Scope Alignment Validation” or “SAV” process).

According to HRSA, the updated forms and the resource materials reflect clarifications of existing policies that should “facilitate accurate documentation of each health center’s scope of project, and ensure ongoing consistency and understanding regarding scope of project for services and sites across the Health Center Program.” The PAL consolidates and clarifies certain service categories (including new service names, as necessary and appropriate) and streamlines / enhances the forms for more simplified data entry. The revised forms also include “interactive descriptors” for each data field (i.e., service category). The resource materials provide additional information, including: (1) descriptions of the general elements for each of the required service categories and for a few additional service categories (including the minimum elements for compliance and a ceiling, above which a Change in Scope request to add a new service would be required); and (2) explanations of the three (3) modes of delivery to assist health centers in determining which service delivery column should be marked on Form 5A.

Changes to Form 5B (Service Sites) include the elimination of redundant and/or unnecessary fields and the addition of two new fields: (1) a required “FQHC Site Medicare Billing Number Status” field; and (2) an optional “FQHC Site National Provider Identification (NPI) Number” field. Similar to Form 5A, HRSA also published an additional resource with instructions describing the information to be entered into each field and clarifying how changes/updates may be made to each field on the form, including which 5B changes necessitate a submission to HRSA and the corresponding level of review.

This PAL is the first of two PALs that will be issued regarding the scope alignment process. HRSA indicated that during the next few weeks, it will issue additional guidance regarding the SAV process. HRSA also anticipates that by late June, health centers will be able to access the new forms containing the migrated data in order to perform the SAV, with a completion / submission date around mid-July. Upon conclusion of the SAV process, all current Forms 5A and 5B will be replaced and the data in the updated forms will be “HRSA’s official record of each health center’s approved scope of project for services and sites.”

Health centers should note that during the time frame for the SAV process, the Change in Scope (CIS) module will be unavailable; while CIS requests submitted prior to that time will continue to be reviewed, health centers will be unable to submit new CIS requests. Further, it is unclear how and the extent to which the transition to the updated scope forms will impact Operational Site Visits (OSVs) scheduled for this summer (in particular, OSVs occurring after the migration of data but before completion of the SAV process). Insofar as HRSA has stated that the updated forms will not become part of the “official record of each health center’s approved scope …” until the SAV process is complete, our present understanding is that the OSV review teams will assess grantees’ scopes of project based on the current forms until such completion occurs. Thus, any health centers attempting to “clean up” their scope forms in advance of and in preparation for an OSV that is scheduled prior to the anticipated SAV completion should continue its efforts and submit all CIS requests as soon as possible.

NACHC has requested that HRSA include in the second PAL clarification about the impact of the SAV process on OSVs that occur during the transition. In the meantime, NACHC will continue to press HRSA for more definitive advice on such impact. Further, NACHC will continue to analyze the updates discussed in the PAL and the resource documents and as necessary, will request HRSA issue additional clarifications.