Policy-Federal
a) HRSA Scope Requirements
Q: Which health centers would be considered eligible to add temporary sites based on the COVID-19 Public Health Emergency? (Added: 3/17/2020)
A: As a result of confirmed cases of 2019 Novel Coronavirus, Secretary of Health and Human Services Azar determined that a public health emergency exists and has existed since January 27, 2020, nationwide. Therefore, HRSA considers all health centers impacted and “eligible” to submit CIS requests to add temporary sites due to an emergency, if necessary.
Q: When do I need to submit a Change in Scope (CIS) request to add a temporary site due to an emergency? (Added: 3/17/2020)
A: HRSA approval is required anytime a health center will add a temporary site(s) in response to emergency events when the location would meet the service site definition as defined in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes. The information needed for this request must be submitted as soon as practicable but no later than 15 days after initiating emergency response activities. HRSA has a streamlined process outlined in PAL 2014-05.
Q: Are there health center emergency response activities that do not require a change in scope?
A: Yes. HRSA approval is not required for the provision of in-scope health center services at the following locations already within the approved scope of project:
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- An approved health center service site (on Form 5B), including the addition of any modular units or trailers on the grounds of the 5B site;
- Mobile units (on Form 5B), including driving mobile units to additional locations in the health center’s service area;
- Home visits (on Form 5C) to health center patients, including visiting health center patients in assisted living facilities and nursing homes;
- Portable clinical care (on Form 5C), where health center staff conduct clinical care outside of health center sites (for example, conducting screenings and consultations in a parking lot, on the street to individuals experiencing homelessness).
- This list of locations is not exhaustive. Please review your scope of project documentation in the EHBs to ensure that Form 5B and Form 5C are up to date.
Q: How do I add a temporary site to help respond to an emergency?
A: Health centers may request a change in scope of project to add a temporary site(s) in response to emergency events through a streamlined process outlined in PAL 2014-05.
b) FTCA Related Issues
Q: How does a health center submit a VHP (volunteer health Professionals) deeming sponsorship application? (Added: 3/19/2020)
A: Health centers can complete a VHP deeming sponsorship application by accessing the Electronic Handbooks (EHBs) and going to the FTCA application section. The EHBs allow sponsoring health centers to submit multiple VHPs in one application submission. For assistance with this process, please contact Health Center Program Support online or at 1-877-464-4772, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays).
Q: Does a health center submit a VHP (volunteer Health Professionals) deeming sponsorship application? (Added: 3/19/2020)an a Primary Care Association (PCA) or another entity submit a VHP deeming sponsorship application on behalf of the health center? (Added: 3/19/2020)
A: No. Applications for VHP deeming must be submitted by the health center’s Authorized Official. However, health centers may seek technical assistance in preparing and submitting such applications from PCAs and other third parties.
Q: Where can I find FTCA guidance related to temporary credentialing and privileging during a declared emergency? (Added: 3/19/2020)
A: See PAL 2017-07: Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations for guidance
Q: Can someone who is employed by one health center volunteer at another health center? (Added: 3/19/2020)
A: Health centers and their providers are strongly encouraged to exercise caution, as FTCA liability protections may be placed at risk when a provider acts on behalf of more than one entity under circumstances that do not make it clear in what capacity the individual was acting at the time of an event that becomes the subject of a claim or lawsuit. Health centers are reminded that when FTCA matters become the subject of litigation, the U.S. Department of Justice and the federal courts assume significant roles in certifying or determining whether a given activity falls within the scope of employment for purposes of FTCA coverage. Health centers and providers are encouraged to consult with private counsel and/or consider the purchase of private malpractice insurance when individual providers wish to undertake activities on behalf of multiple entities and/or in multiple capacities.
c) BPHC Data Collection Guidance:
Q: What data reporting is HRSA requesting from health centers during the COVID-19 emergency response? (3/19/2020)
A: HRSA is asking health centers to begin filling out a twice-weekly survey to help track the number of patients who have undergone COVID-19 testing at each health center, along with other critical information about health center operations during the pandemic. Each health center will receive an electronic, easy to use survey (reducing the need for telephonic, email, or other methods of gathering critical COVID-19 related information) twice a week on Monday and Thursday afternoons via email from BPHCanswers@hrsa.gov.
Q: What is the reporting period for the survey?
A: For the report due Tuesday afternoons, please report on activities from Friday of the previous week through Monday. For the report due Friday afternoons, please report on activities from Tuesday through Thursday. The survey includes questions on activities during the reporting period as well as cumulative.
Q: Who from my health center should complete this survey?
A: The survey is sent to the Project Director listed in EHBs, but that person can also forward their unique link to anyone in the organization who can report.
Q: If my health center is experiencing particular challenges due to COVID-19, can I report this information through the survey?
A: Yes. The survey includes an opportunity to provide additional information, comments, or challenges you are experiencing due to COVID-19.
Q: How will the information from the survey be used?
A: HRSA will use the information collected to assess health centers’ needs throughout the COVID-19 response, to share critical information related to testing, cases, and impacts at health centers, and to better understand training and technical assistance, funding, and other resource needs.
Q: What if our health center has questions while completing the survey?
A: Please contact Health Center Program Support online or at 877-464-4772, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays). If you use the online form, select “Coronavirus Inquiries (COVID-19)” as the issue type.
d) Proposed Policy Waivers
e) FIT Testing
f) Laws re COVID-19
Policy-State
a) Proposed Policy Waivers
b) CHIP
Operational
a) CHC OSV Request for Cancellations and Rescheduling
- As per HRSA website, BPHC is monitoring and following the recommendations of the CDC. With that in mind, and given the importance of health centers in the local, state and national response efforts, BPHC will postpone all planned site visits until a later date to be determined. This decision is made in consideration of the potential impact to health center operations during the COVID-19 outbreak, BPHC staff and consultants, as well as the need for staff to be available for immediate mission critical assignments.
- OSVs and other site visits are an important part of the Health Center Program monitoring and oversight process; therefore, BPHC will reschedule the postposed OSVs and all other site visits as soon as is practical (dated: 3/17/2020).
b) HRSA Grant Work Plan Deliverables
- In general, health centers are expected to plan for the provision of ongoing, continuing preventive and primary care to their patients. HRSA recognizes that during declared emergencies health centers may face staffing shortages and/or facility capacity limitations and may need to prioritize appointments and staffing to address the most urgent needs of patients. No change in scope is necessary if your health center is changing the level or intensity of certain services within the scope of project. If a health center permanently removes a service from its scope of project, a change in scope request to delete the service will need to be submitted for HRSA approval (HRSA update dated 3/17/20).
Access
a) Telehealth Barriers and Waivers
b) Telehealth – Frequently Asked Questions:
Q: Can health centers conduct screening or triage of health center and non-health center patients outside of the health center’s service sites? (Added: 3/19/2020)
A: Yes. Screening or triage of health center patients performed on behalf of the health center are elements of general primary care as reflected on Form 5A: Services Provided. The Health Center Program views providing screenings and triage to any patient — including both established health center patients and to individuals who are not established patients of the health center – at the health center, outside on its grounds, or elsewhere in the community as within the health center’s scope of project (see 42 CFR 6.6 (e)(4)(i)(C)). This includes providing such screening and triage to patients in the parking lot of the health center or in other community locations.
Q: May health centers provide in-scope services through telehealth to individuals who are not current health center patients? (Added: 3/19/2020)
A: As a result of the Secretary’s declaration relating to the current COVID-19 public health emergency, during the duration of this public health emergency health center providers may deliver in-scope services via telehealth to individuals who have not previously presented for care at a health center site and who are not current patients of the health center. Telehealth visits are within the scope of project if:
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- The individual receives an in-scope required or additional health service;
- The provider documents the service in a patient medical record consistent with applicable standards of practice; and
- The provider is physically located at a health center service site or at some other location on behalf of the health center (e.g., provider’s home, emergency operations center).
Health centers should focus services provided by telehealth on serving patients and other individuals located inside their service area or with areas adjacent to the covered entity’s service area. It is recognized that in the current public health emergency situation, patients outside these areas may seek health center screenings and triage by telehealth. Health centers that continue to maintain services for target populations in their service area and provide occasional in-scope services via telehealth to individuals outside these areas would be providing services within the Health Center Program scope of project for all such activities.
Policies and Procedures
a) New Procedures Required
b) Center Best Practices Sharing Forum
c) Guidance
Testing
a) Availability
b) Drive Thru Testing and Scope
