Health Center Regulatory Issues

HRSA issues PAL on Updated Change in Scope Process

On August 28, 2014, HRSA issued Program Assistance Letter #2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines. The PAL expands on clarifications in PAL 2013-03, issued last year, and applies to both grantees and FQHC look-alike entities. Specifically, the PAL clarifies the following timelines:

  • Submission of Complete Change in Scope (CIS) Requests. Health centers should submit complete CIS requests (i.e., requests that include all information requested by HRSA) at least sixty (60) days prior to the desired implementation date. HRSA will notify the health center of its final decision within sixty (60) days of receiving a complete request.
  • Requests for Additional Information. If necessary for evaluation of the CIS request, HRSA may request additional or clarifying information through a “Change Request” in the EHB. In those cases, HRSA may extend the review process beyond the sixty (60) day time frame to account for the time necessary for the health center to submit, and for HRSA to review, the additional information.
  • Other Review Process Extensions. HRSA also may extend the sixty (60) day review if additional analysis is necessary, regardless of whether additional information is submitted. Examples include situations that require a service area overlap analysis.
  • Deactivation of Inactive CIS Request. If a CIS submission is initiated but not completed by the grantee within sixty (60) days or if the health center does not respond to a request for additional information within sixty (60) days of the request, HRSA will “deactivate” the CIS request. If the health center wants to proceed with the request, it will be required to submit a new CIS request.

In a change from existing policy, the effective date for a CIS will no longer reflect the date that a complete request was received by HRSA. Rather, the effective date will be the date that BPHC recommends approval of the CIS request. Grantees will receive a Notice of Award approving the CIS, while FQHC look-alikes will receive notification of the approval via the EHB. If the request is not approved, HRSA will inform the health enter via EHB notification.

Finally, the PAL reflects existing policy regarding implementation – health centers are required to implement an approved CIS after the effective date but within 120-days of receiving approval and must verify through the EHB that such implementation took place. HRSA emphasizes that the verification step must be completes to be officially documented in the health center’s scope of project.

Please do not hesitate to contact us should you have any questions on this or any other issues.