Form 29 Checklist for Adding a New Service Delivery Site - track

The Health Center Program Application Forms

Checklist for Adding a New Service Delivery Site - track changes

Checklist for Adding a new Service Delivery Site

OMB: 0915-0285

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OMB No.: 0915-0285. Expiration Date: xx/xx/xxxx

Checklist for Adding a New Service Delivery Site



Assurances:

  • I certify that the following statements related to the preparation of this Change in Scope (CIS) request are true, complete and accurate:


  • The health center consulted with its Project Officer prior to submitting this CIS request.


  • The proposed CIS implementation date is at least 60 days from the submission date to HRSA. Note: HRSA recognizes that there may be circumstances where submitting a CIS request at least 60 days in advance of the desired implementation date may not be possible; however, the goal is to minimize these occurrences through careful planning. Refer to http://www.bphc.hrsa.gov/policiesregulations/policies/pdfs/pal201410.pdf)


  • The health center’s governing board approved this CIS request prior to submission to HRSA, as documented in board minutes (must be made available upon request).


  • The health center has examined the potential impact of this CIS under the requirements of other programs as applicable (e.g., 340B Program, FTCA).


  • The health center understands that HRSA will consider its current compliance with Health Center Program requirements and regulations (i.e., the status and number of any progressive action conditions) when making a decision on this CIS request. (See PAL: 2014-08 Health Center Program Requirements Oversight for more information on progressive action).

  • I will ensure the health center complies with the following statements related to the implementation of this Change in Scope (CIS) request, if approved:

  • All Health Center Program requirements (http://www.bphc.hrsa.gov/programrequirements/index.html) will apply to this CIS. Note: Compliance with Health Center Program requirements across sites and services will be assessed through all appropriate means, including site visits and application reviews.


  • This CIS will be undertaken directly by or on behalf of the health center for the benefit of the current or proposed health center patient population, and the health center’s governing board will retain oversight over the provision of any services and/or sites.


  • This CIS will be accomplished without additional Health Center Program Federal award funding and will not shift resources away from carrying out the current HRSA-approved scope of project.


  • The impact of this CIS will be reflected in the total budget submitted with the health center’s next annual competing or non-competing or designation application.



  • This CIS will not diminish the patient population’s access to and quality of services currently provided by the health center.


  • No additional changes in scope are necessary to implement this CIS (e.g., approval of a new site does not entail approval of any new services to be provided at the new site).


  • The health center will take all applicable steps related to the requirements of other programs impacted by this change in scope request.





Change in Scope Questions:



Is this request to add a site linked to another recently submitted, in progress or planned CIS request? (e.g., the health center will be moving operations to this new site and will submit a CIS request to delete a current site; the health center will provide a service not currently in scope at this site and will submit a CIS request to add the service)

Y/N – require text box explanation if Y

  1. NEED AND RATIONALE: Discuss why and how the addition of the proposed site will address unmet need by maintaining or increasing access and maintaining or improving quality of care for the patient population.

    1. Provide evidence that the proposed site will address unmet need by maintaining or increasing access to care for the population that will utilize the new site. Provide data only for the new site.

Total unserved low-income population in the proposed service area _____

Source __________

If these data/source are not consistent with the UDS Mapper map and data table, please explain: ____________

Total number of patients projected to be served annually:

New patients____

Existing patients____

Of the total projected patients, anticipated % of patients with incomes at or below 200% of the Federal Poverty Guidelines: ____

Briefly explain how these projections were derived: ____________



Required Attachment: UDS Mapper Map & Data Table

Optional Attachment: Other Supporting Need Documentation



NOTE: The UDS Mapper Map and Data Table are required and should be used to support the explanations provided in this CIS request; upload any additional need data/documentation as necessary. HRSA will use UDS Mapper data to assess unmet need and service area overlap. If UDS Mapper Map and Data Table are not yet available, attach other relevant and comparable documentation which supports this request. UDS Mapper: http://www.udsmapper.org. For a UDS Mapper sample to support a CIS request, click here (placeholder for external resource).

    1. What is the unmet need/justification for the proposed site? Select all that apply

  • This is a comparable replacement site for an existing site awarded via a funding opportunity (e.g., New Access Point) that is no longer available. Note: The proposed site must serve the same zip codes and be comparable in terms of patient capacity to the site originally proposed in the approved application.

Provide the relevant application number: ___

  • The proposed service area has a Health Center Program (grantees and look-alikes) penetration rate for the low-income (below 200% of the Federal Poverty Guidelines) population at or below 25% as evidenced by the attached UDS Mapper data (i.e., 75% or more of the proposed service area’s low-income population is not served under the Health Center Program).

  • The health center is exceeding capacity at a current location(s).

  • The health center is already serving a high number of patients from the proposed service area.

  • An existing provider is closing a site and/or no longer offering services to the patient population in the area.

  • One or more of the health center’s existing sites is under renovation and a temporary service site is needed until the renovations are complete. Note: if the temporary site will no longer be utilized once the existing site(s) re-opens, a CIS request to delete the temporary site from scope must be submitted.

  • Other Need/Special Circumstance (e.g. high level of chronic conditions in the low income population, gaps in coverage among different population groups, special population, limited service site need)

    1. Provide a brief discussion, as appropriate, for the selection of the proposed site in terms of:

  • Relevant background information (e.g., adding site in response to: operational site visit finding, health center strategic plan, special funding obtained)

  • Reason for location type (e.g., permanent, mobile)

  • Rationale for site hours of operation (e.g., part-time versus full-time)

  • Rationale for types of services to be offered at the site (e.g., medical, oral , mental health)

  • Description if the proposed site will offer limited services (e.g., dental-only, behavioral health-only) or services to limited patient groups (e.g., school-aged children), of:

    • How all individuals who present for services at this site will have access to the full scope of health center required and additional services; and/or

    • How all individuals who are not among the limited group served by the site and who present at this site for care will be referred to other appropriate health center sites to receive services not available at the proposed site.



Requires narrative response.



Proposed Date of Site Addition: mm/dd/yyyy



Note: Please review Program Assistance Letter 2014-10: Updated Process for Change in Scope Submission, Review and Approval Timelines and Policy Information Notice 2008-01: Defining Scope of Project and Policy for Requesting Changes. In cases where a health center is not able to determine the exact date by which a CIS will be fully accomplished, BPHC will allow up to 120 days following the date of the CIS approval Notice of Award (NoA) or look-alike Notice of Look-Alike Designation (NLD) for the health center to implement the change (e.g., open the site). Review the Program Assistance Letter 2009-11: New Scope Verification Process for more information.

  1. SERVICE AREA: Explain the proposed service area, existing safety net resources, and how the proposed new site will complement and not duplicate these existing resources.

Based on UDS Mapper Map and Data Table information, will the site serve all or part of a service area currently served by another health center grantee or look-alike and/or of another primary care safety net provider (rural health clinic, critical access hospital, health department, etc.)? Yes or No. Checkboxes for Yes options to allow multiple selections; No skips narrative; Any Yes response requires narrative response.

  • No

  • Yes – the site will serve a newly identified sub-group/underserved population (e.g., people experiencing homelessness, populations with limited English proficiency within the service area), whose health care needs are not being met.

  • Yes – the site will serve an area where unmet need exceeds the capacity of the existing health center site(s) and/or other safety net providers.

  • Yes – the site will serve a population where the distance and travel time to the nearest safety-net provider site, (e.g., health center grantee or look-alike, rural health clinic, critical access hospital) is a barrier for patients to access care. Note: UDS Mapper is the best tool for identifying the nearest Health Center Program grantee or look-alike. Distance should be measured as the distance (in miles) from the address of the proposed service site to the nearest Health Center Program grantee or look-alike service sites. Use the UDS Mapper Distance tool and/or Google Maps to determine (1) the distance in miles between sites and (2) travel time by driving or public transportation, as appropriate (e.g., if at least 30% of the patient population uses public transportation as the main source of transportation to work, provide travel time based on public transport as opposed to providing travel time by car/drive time).

    • Distance in miles: _____

    • Travel time in minutes: _____

Required for any Yes response:

Based on this answer and attached UDS Mapper data and other needs assessment documentation that shows other health centers and service providers and their penetration rates, address any service area overlap and how the proposed site will complement existing services and programs so as to minimize the potential for unnecessary duplication and/or overlap in services, sites or programs.

Requires narrative response.



Note: Upload any relevant letters of support from all health centers serving the same service area in the next section

  1. COLLABORATION WITH HEALTH CENTERS AND OTHER SAFETY NET PROVIDERS

For the purposes of this question, collaborative relationships are those that contribute to one or both of the following goals relative to the proposed site:

(1) maximize access to required and additional services within the scope of the health center project for patients that will be served at the proposed site; and/or

(2) promote the continuity of care of patients that will be served at the proposed site by coordinating with the services and activities of other federally funded, as well as State and local, health services delivery projects and programs serving the same or a similar patient population (e.g., other health centers, rural health clinics, hospitals, health departments).

  1. Describe the established and/or proposed collaboration with other health centers and safety net providers (e.g., health departments, rural health clinics, hospitals) within and adjacent (e.g., neighboring ZIP codes) to the service area for this proposed site and how this collaboration will benefit the proposed patient population to be served.

Requires narrative response.

  1. Attach documentation of collaboration, including any agreements (e.g., MOA, MOU, contract), relevant and specific to the proposed site which support the response to 3a. If documentation could not be obtained, describe the outreach made to these service area providers concerning this proposed site and the result of this outreach.

Optional narrative response:

Optional attachment: Documentation of Collaboration

  1. SITE OWNERSHIP/OPERATION (not required if site operated directly by health center)

FOR SITES OPERATED BY CONTRACT: If the proposed site is operated by a third party on behalf of the health center through a written contractual agreement between the health center and the third party (i.e., the health center is contracting with a third party for part or full operation of this service site):

  • Provide the rationale for operating the site through a contract (as opposed to the health center operating the site directly); and

  • Explain why this third-party organization was selected to operate the proposed site (e.g., contractor’s capabilities and resources, experience with health center patient population).

Requires narrative response

No attachment requested/required



Resources:

Procurement Standards: http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=0386f369acd20f0e943466135faeed0b&r=PART&n=pt45.1.75#sg45.1.75_1324_675_1325.sg2

Contract: A contract is used for the purpose of obtaining goods and services for the health center’s own use and creates a procurement relationship with the contractor. Characteristics indicative of a procurement relationship between the health center and a contractor are when the contractor:

  1. Provides the goods and services within normal business operations;

  2. Provides similar goods or services to many different purchasers;

  3. Normally operates in a competitive environment;

  4. Provides goods or services that are ancillary to the operation of the federal program; and

  5. Is not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons.

For more information on determining whether an agreement for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor, please review 45 CFR 75.351. Please note that contractors are not able to qualify as federally qualified health centers. See http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=0386f369acd20f0e943466135faeed0b&r=PART&n=pt45.1.75

FOR SITES OPERATED BY SUBRECIPIENTS: If the proposed site is operated by a third party on behalf of the health center through a written subrecipient agreement between the health center and the subrecipient organization (i.e., the health center is providing a subaward to the organization to perform a substantive portion of the grant-supported program or project for the operation of the proposed site):

  • Provide the rationale for operating the site through a subaward (as opposed to the health center operating the site directly);

  • Describe actions taken to confirm that the subrecipient organization complies with all Health Center Program requirements and the terms and conditions of the federal award; and

  • Describe actions for ongoing monitoring of the subawardee (as indicated in the attached subrecipient agreement) to ensure maintenance of Health Center Program requirements and the terms and condition of the federal award.

Requires narrative response

Required attachment: Subrecipient agreement



Resources - Subcrecipient Monitoring and Management:

http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=0386f369acd20f0e943466135faeed0b&r=PART&n=pt45.1.75#sg45.1.75_1344_675_1350.sg4

  • Subaward: An award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.



  • Pass-Through Entity: A non-federal entity that provides a subaward to a subrecipient to carry out part of a federal program.



  • Subrecipient: A non-federal entity that receives a subaward from a pass-through entity to carry out part of a federal program and is accountable to the recipient for the use of the funds provided but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency.

  • Characteristics which support the classification of the non-federal entity as a subrecipient include when the non-federal entity:

  • Determines who is eligible to receive what federal assistance;

  • Has its performance measured in relation to whether objectives of a federal program were met;

  • Has responsibility for programmatic decision making;

  • Is responsible for adherence to applicable federal program requirements specified in the federal award; and

  • In accordance with its agreement, uses the federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.



For more information on determining whether an agreement for the disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor, please review 45 CFR 75.351. See http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=0386f369acd20f0e943466135faeed0b&r=PART&n=pt45.1.75



Subrecipients are generally eligible to receive FQHC reimbursement under Medicaid and Medicare, 340B Drug Pricing, and FTCA coverage. However, such benefits are not automatically conferred and may require additional actions and approvals (e.g., submission and approval of a subrecipient deeming application).



Public Burden Statement: An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control number for this project is 0915-0285. Public reporting burden for this collection of information is estimated to average 1.5 hours per response, including the time for reviewing instructions, searching existing data sources, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to HRSA Reports Clearance Officer, 5600 Fishers Lane, Room 14N-39, Rockville, Maryland, 20857.



Change Checklist






DEPARTMENT OF HEALTH AND HUMAN SERVICES
Health Resources and Services Administration

CHECKLIST FOR ADDING A SITE (CHKLST003)

Grantee Name:

Grantee Number:

CIS Tracking Number:





Questions for Addition of Site

Site Name


Site Address


When do you plan to start providing services at the site?











1. NEED
Clearly address why and how the addition of the proposed site will address unmet need and further the mission of the health center by
maintaining or increasing access and maintaining or improving quality of care for the target population.

1a. How was the need for the proposed site identified (check all applicable reasons)?


UDS Trend Data (e.g. Patient Origin Data) and/or a needs assessment indicated a high need for a site at this location (e.g. health center is exceeding patient capacity at existing sites, health center is seeing significant number of patients from the proposed area).
UDS Data Year (20
) Needs assessment completed on (mm/dd/yyyy):
The site is located in a Medically Underserved Area (MUA). The site is located in a Medically Underserved Area (MUA).
Health center verified MUA Designation is current in
HRSA Database on (mm/dd/yyyy):
The site will serve a Medically Underserved Population (MUP). The site will serve a Medically Underserved Population (MUP).
Health center verified MUP Designation is current in
HRSA Database on (mm/dd/yyyy):
An existing health center site (section 330 grantee or FQHC Look-Alike) in the proposed area is closing and/or another safety net provider(s) is no longer offering services to our target population in this area.
One or more of my current sites is under renovation and we need to add a temporary site to scope where we will provide services until the current site(s) under renovation are ready. Once the health center re-opens the existing site in scope that is currently under renovation, if they will no longer be utilizing the temporary site added through this change in scope, they will need to submit a change in scope to REMOVE the temporary site from scope via a Site Deletion request.
The site will replace a site I have already removed from scope and/or plan to remove from scope in the future, and these two actions (closure of original site and opening of new site to replace the original site) will NOT be accomplished within 120 days or less.
Other (Describe in the space provided below):
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

1b. Using the most recent UDS data and/or other data specific to your target population and/or service area, describe the:

  • specific access barriers (e.g. Ratio of Population to One FTE Primary Care Physician, Distance (miles) OR Travel Time (minutes) to Nearest Primary Care Provider Accepting New Medicaid and/or Uninsured Patients: private practitioner, health center, etc.) and

  • specific risk factors (e.g., occupational, environmental, behavioral, social/cultural, or housing status) of the patient population to be served at the proposed site that supports the need for and/or benefit of the proposed site.


Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

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1c. Provide evidence that the proposed site will appropriately serve the current patient and/or target population by providing the following information about the population that will utilize the new site.

Number of patients projected to be served annually
This is the anticipated number of patients that will utilize the proposed site in the coming calendar year.

Number:

(Format: 99)

Data Source Used for Projection:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

Percentage of projected patients at or below 200% of Federal Poverty Guidelines
This is the anticipated % of patients with incomes at or below 200% of the Federal Poverty Guidelines that will utilize the proposed site in the coming calendar year.

Percentage:
%
(Format: 9 or 9.99)

Data Source Used for Projection:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

Percentage of projected uninsured patients
This is the anticipated % of uninsured patients that will utilize the proposed site in the coming calendar year.

Percentage:
%
(Format: 9 or 9.99)

Data Source Used for Projection:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

1d.Provide a brief narrative description on how the projections in 1c. were derived.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

2. Service Area Analysis:

Describe how the health center has analyzed the service area, utilizing UDS Mapper and/or other similar resources, where the proposed site will be located. (Attach analysis documentation)
Responses should be consistent with data and narrative on unmet need and projected patients provided in Question 1.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)




Service Area Analysis (Maximum 6 attachments)

Select

Purpose

Document Name

Size

Uploaded By

Description

No attached document exists.





Service Area Analysis Resources
Service Area Overlap Policy and Process:
http://bphc.hrsa.gov/policiesregulations/policies/pin200709.html
UDS Mapper:
http://www.udsmapper.org
HRSA Data Warehouse:
http://datawarehouse.hrsa.gov

Click "Save" button to save all information within this page.



2a. Select the appropriate statement. The proposed site is being added to:

For the purposes of this question:

  • Service area is defined by the service area zip codes associated with your Form 5B sites.

  • Patient population is defined by your current UDS Patient Origin Data.

  • Target population is defined in your most recent approved application.



provide increased access and/or capacity for the existing patient/target population within the existing service area. Continue to Question 3.

provide increased access in whole or in part to a new patient/target population and/or a new service area that is not currently served by your health center. Continue to Question 2b.



Provide comments related to selection
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

2b. Will the proposed site serve all or part of the service area of another health center (section 330 grantee or Look-Alike) and/or of another primary care safety net provider (rural health clinics, critical access hospitals, health departments, etc.)?



Yes

No

N/A




If Yes, list these other health centers and/or safety net providers and discuss how the proposed site will complement these existing primary care resources so as to minimize the potential for unnecessary duplication and/or overlap in services, sites, or programs. Continue to 2c only if the site will serve all or part of the service area of another health center (section 330 grantee or Look-Alike). Otherwise, continue to Question 3.

If No, continue directly to Question 3.

Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

2c. As the proposed site will serve all or part of the service area of another health center, discuss if and how one or more of the following apply to your proposal (See PIN 2007-09: Service Area Overlap Policy and Process for more information on HRSA’s principles for assessing individual situations of service area overlap):

  • The proposed site will serve a newly identified sub-group of underserved people within a community already served by another health center(s) site(s) (e.g., homeless people, populations with limited English proficiency within the service area), where the health care needs of the relevant medically underserved population group within the new service area are not being met by another health center’s site(s).

  • The proposed site will serve an area where unmet need exceeds the capacity of the existing health center's site(s) in the new service area.





Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

Once completed, continue to Question 3.



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3. Service Area Collaboration

For the purpose of this question:
Collaborative relationships are those that assist in contributing to one or both of the following goals relative to the proposed site:
(1) maximizing access to required and additional services within the scope of the health center project to the target population that will be served at the proposed site; and/or
(2) promoting continuity of care to health care services for health center patients served at the proposed site beyond the scope of the project.


Collaboration Resources
Collaboration PAL:
http://bphc.hrsa.gov/policiesregulations/policies/pal201102.html
UDS Mapper:
http://www.udsmapper.org

3a. Describe established collaboration and new collaborative efforts under development with existing health centers (section 330 grantee and Look-Alikes) within or adjacent to the service area of the proposed site. In addition, list the names and addresses of these health centers and/or refer to the attached Service Area Analysis from Question 2 if listed there). If service area collaboration has already been discussed in Service Area Analysis Question 2b, refer back to these responses.

If a formal affiliation (e.g. MOA, MOU, contract, etc.) and/ or letter of collaboration or support from the neighboring health center(s) is available, attach these documents below. Only documents that speak to the proposed change in scope request for the site addition should be included.

If no other health centers exist within or adjacent to the service area state this.
If documentation of collaboration or support from service area health centers cannot be obtained, include documentation of efforts made to obtain such documents and an explanation for why they could not be obtained.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)




Collaboration Documentation (Maximum 6 attachments)

Select

Purpose

Document Name

Size

Uploaded By

Description

No attached document exists.





3b. Describe established collaboration and new collaborative efforts under development with other safety net providers (e.g. rural health clinics, critical access hospitals, health departments, etc.) within or adjacent to the service area of the proposed site. In addition, list the names and addresses of these other safety net providers and/or refer to the attached Service Area Analysis from Question 2 if listed there). If service area collaboration has already been discussed in Service Area Analysis Question 2b, refer back to these responses.

If a formal affiliation (e.g. MOA, MOU, contract, etc.) and/or letter of collaboration or support
relevant to the proposed site addition is available, attach these documents below. Only documents that speak to the proposed change in scope request for the site addition should be included.
If no other safety net providers exist within or adjacent to the service area state this.
If documentation of collaboration or support from service area safety net providers cannot be obtained, include documentation of efforts made to obtain such documents and an explanation for why they could not be obtained.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)




Collaboration Documentation (Maximum 6 attachments)

Select

Purpose

Document Name

Size

Uploaded By

Description

No attached document exists.





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4. Governance

Discuss whether the addition of the proposed site will have any impact on the health center’s ability to maintain compliance with the Health Center Program Board Composition
Governance Requirements.

Consider and discuss any plans to address, the following applicable aspects of the Board Composition Requirement that may be impacted by a site addition:

  • Will the addition of the new site significantly change the overall demographics of the patients served by the health center as a whole (i.e. across all sites) in terms of race, ethnicity and sex and thus potentially impact the representativeness of the composition of the health center’s current patient majority governing board (unless waived for Health Center Program grantees funded and look-alikes designated only under sections 330(g), (h), and/or (i) of the Public Health Service (PHS) Act)?

  • Will the addition of the new site significantly change the size and complexity of the overall health center organization and potentially create the need to recruit additional patient and/or non-patient board members (i.e. increase the board’s size)?

  • Will the addition of the new site impact the need to recruit additional non-patient board members with expertise in areas not currently reflected on the board?



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

5. Site Ownership and Operation:

For sites that will be operated through a contractual or subrecipient arrangement (i.e. not directly by the health center):

Will services at the contracted or subrecipient operated site be provided on behalf of the health center to health center patients?



Yes

No



Will the health center’s governing board retain control and authority over the provision of the services to health center patients at the contracted or subrecipient operated site?



Yes

No



Briefly justify why the health center has chosen to operate the site through such third party arrangements.

Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)


Health centers are reminded of their responsibilities to obtain any required prior approval from HRSA for aspects of the program conducted by subrecipients or contractors before a subrecipient or contractor can undertake an activity or make a budget change requiring that approval e.g., approval to extend the period of performance of a subaward to a subrecipient if it would extend beyond the end of the grant’s project period).

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5a. FOR SITES OPERATED BY CONTRACT: If the proposed site is owned and/or operated by a third party on behalf of the health center through a written contractual agreement between the health center and the third party (i.e. the health center is purchasing a specific set of goods and services from the third party-such as the operation of a site), does the contract state, address or include:

The activities to be performed by the contractor in the operation of the site, specifically including:

  • How the services provided at the site will be documented in the health center patient record?

  • How the health center will bill and/or pay for the services provided to health center patients at the site?



Yes

No


List Page #(s):

The time schedule for such activities (e.g. hours of site operation)?



Yes

No


List Page #(s):

The policies and requirements that apply to the contractor, including those required by 45 CFR 74.48 or 92.36(i) and other terms and conditions of the grant? These may be incorporated by reference where feasible – See the HHS Grants Policy Statement for more information on public policy requirements applicable to contractors at: http://www.hrsa.gov/grants/hhsgrantspolicy.pdf pages II-2 to II-6



Yes

No


List Page #(s):

The maximum amount of money for which the health center may become liable to the third party under the agreement?



Yes

No


List Page #(s):

Provisions consistent with the health center’s board approved procurement policies and procedures in accordance with 45CFR Part 74.41-48?



Yes

No


List Page #(s):

Assurances that no provisions will affect the health center’s overall responsibility for the direction of the site and services to be provided there and accountability to the Federal government by reserving sufficient rights and control to the health center to enable it to fulfill its responsibilities?



Yes

No


List Page #(s):

Requirements that the contractor maintain appropriate financial, program and property management systems and records and provides the health center, HHS and the U.S. Comptroller General with access to such records, including the submission of financial and programmatic reports to the health center if applicable and comply with any other applicable Federal procurement standards set forth in 45CFR Part 74 (including conflict of interest standards)?



Yes

No


List Page #(s):

Provision that such agreement is subject to termination (with administrative, contractual and legal remedies) in the event of breach by the contractor?



Yes

No


List Page #(s):


It is the responsibility of the health center to ensure that the contract does NOT inappropriately imply the conference of the benefits and/or privileges of the Health Center Program grantees or FQHC Look-Alikes such as 340B Drug Pricing or FQHC reimbursement, on the other party.

Attach the contract for the site (draft agreements are acceptable) here.






Contract for the site (Maximum 6 attachments)

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5b. FOR SITES OPERATED BY SUBRECIPIENTS: If the proposed site is owned and/or operated by subrecipient on behalf of the health center through a written subrecipient agreement between the health center and the subrecipient organization to perform a substantive portion of the grant-supported program or project, respond to all of the following questions.

A subrecipient is an organization that “(ii)(I) is receiving funding from such a grant under a contract with the recipient of such a grant, and (II) meets the requirements to receive a grant under section 330 of such Act . . .” (§1861(aa)(4) and §1905(l)(2)(B) of the Social Security Act).

  • Subrecipients must be compliant with all of the requirements of section 330 to be eligible to receive FQHC reimbursement from both Medicare and Medicaid.

  • The subrecipient arrangement must be documented through a formal written agreement (Section 330(a)(1) of the PHS Act)

The health center (grantee of record) named on the NoA is the entity legally accountable to HRSA for performance of the project or program, the appropriate expenditure of funds by all parties including subrecipients, and other requirements placed on the health center (grantee of record), regardless of the involvement of others in conducting the project or program.

Has the health center’s key management staff confirmed that the subrecipient meets
all applicable section 330 requirements and does the health center’s key management staff and its governing board have a plan in place to monitor the subrecipient's compliance over time?



Yes

No



Does the board-approved subrecipient agreement state, address or include the following elements necessary for meeting the programmatic, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies:

Identification of the PI/PD and individuals responsible for the programmatic activity at the subrecipient organization along with their roles and responsibilities?



Yes

No


List Page #(s):

Procedures for directing and monitoring the programmatic effort?



Yes

No


List Page #(s):

Procedures to be followed in providing funding to the subrecipient, including dollar ceiling, method and schedule of payment, type of supporting documentation required, and procedures for review and approval of expenditures of grant funds?



Yes

No


List Page #(s):

If different from those of the recipient, a determination of policies to be followed in such areas as travel reimbursement and salaries and fringe benefits (the policies of the subrecipient may be used as long as they meet HHS requirements)?



Yes

No


List Page #(s):

Incorporation of applicable public policy requirements and provisions indicating the intent of the subrecipient to comply, including submission of applicable assurances and certifications? See the HHS Grants Policy Statement for more information on public policy requirements applicable to subrecipients at: http://www.hrsa.gov/grants/hhsgrantspolicy.pdf pages II-2 to II-6



Yes

No


List Page #(s):

Attach the subrecipient agreement documentation (draft documents are acceptable) here.






Subrecipient Agreement (Maximum 6 attachments)

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Subrecipients are eligible to receive FQHC reimbursement as well as many of the other benefits and privileges of the Health Center Program grantees and Look-Alikes such as 340B Drug Pricing, FTCA coverage (section 330 grantees only).However, the health center AND subrecipient organization are reminded that such benefits are not automatically conferred and may require additional steps and updates (e.g. updating the FTCA deeming folder to ensure that the subrecipient is deemed via the grantee of record’s FTCA coverage).

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6. SERVICES:
Are all the services that will be offered at the proposed site already included within the approved scope of project as documented on your health center’s Form 5A



Yes

No, but a separate CIS Request will be submitted to add all new services to scope.



7. LIMITED SERVICE SITES

Is this a limited service sites that will not offer comprehensive primary care or will not be open to the entire health center patient population (e.g. sites that offer only oral or behavioral health services, sites that are only open to school-aged children, etc.):

How will patients seen at this proposed site be assured access to the full scope of existing required and additional services the health center provides? Please explain

Yes

No





If Yes, explain and address all of the following points as applicable.

  • If the site is limited to a certain segment of the health center’s patient population (e.g. school-aged children), how will individuals who present for services at this site be referred to another appropriate health center site for services?

  • If the site offers only limited services (e.g. dental-only), how will individuals seen at this site access the full scope of existing required and additional services the health center provides?



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



8. SLIDING FEE DISCOUNT PROGRAM:
Will the health center offer its current sliding fee discount program (sliding fee discount schedule, including any nominal fees and related implementing policies and procedures) at the proposed site to patients with incomes at or below 200 percent of the Federal Poverty Guidelines, and ensure that no patients will be denied access to the service due to inability to pay?



Yes

No


If No, briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

9. Financial Impact Analysis

Template Name

Template Description

Action

Financial Impact Analysis

Template for Financial Impact Analysis

Instructions

Instructions for Financial Impact Analysis





Attach Financial Impact Analysis Document here.




Financial Impact Analysis (Maximum 6 attachments)

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9a. Explain how the addition of the proposed site to scope will be accomplished and sustained without additional section 330 Health Center Program funds. Specifically (referencing the attached Financial Impact Analysis, as necessary) describe how adequate revenue will be generated to cover all expenses as well as an appropriate share of overhead costs incurred by the health center in administering the new site.

The Financial Impact Analysis must at
a minimum show a break-even scenario or the potential for generating additional revenue.

Additional revenue (program income) obtained through the addition of a new site must be invested in activities that further the objectives of the approved health center project, consistent with and not specifically prohibited by statute or regulations.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

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9b. Is this change in scope dependent on any special grant, foundation or other funding that is time-limited, e.g., will only be available for 1 or 2 years?



Yes

No


If Yes, how will the new site be supported and sustained when these funds are no longer available? Describe a clear plan for sustaining the site.

Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)


All time-limited or special one-time funds should be clearly identified as such in the Financial Impact Analysis.

10. STAFFING:
Provide a clear and comprehensive description of the relevant staffing arrangements made to support the proposed new site and to ensure staffing is/will be sufficient to meet any projected patient/visit increases. The discussion of “staffing” should include non-health center employees if the site will be operated via contract or subrecipient arrangement. In addition, describe any potential impact on the overall organization’s staffing plan (reference the Financial Impact Analysis as applicable). Specifically describe any key management staff that will supervise/oversee site operations and who they will report to within the larger health center organizational structure (e.g. CMO, COO, etc.).



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

11. HEALTH CENTER STATUS: Discuss any major changes in the health center’s staffing, financial position, governance, and/or other operational areas, as well as any unresolved areas of non-compliance with Program Requirements (e.g. active Progressive Action conditions) in the past 12 months that might impact the health center’s ability to implement the proposed change in scope.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

12. CREDENTIALING AND PRIVILEGING:
How has the health center planned for the appropriate credentialing and privileging of
all provider(s) that will staff the proposed site in accordance with PIN 2002-22?

In responding, consider the following:

  • It is the responsibility of the health center to ensure that all credentialing and privileging of providers has been completed BEFORE providing services at the new site as part of their Federal scope of project. This includes services provided either Directly (Form 5A: Column I) OR via a (Form 5A: Column II) Formal Written Agreement (e.g. contract). For services provided via a Formal Written Referral Arrangement (Column III), the referral provider should be able to assure to the health center that all their providers are appropriately credentialed and privileged individually.

  • The health center’s current board-approved policy must cover the required verification of credentials and establishment of privileges to perform any new activities and procedures expected of providers by the health center or be updated to do so (for services provided at the new site either Directly (Form 5A: Column I) OR via a (Form 5A: Column II) Formal Written Agreement.



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)

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13. QUALITY IMPROVEMENT/ASSURANCE PLAN:
How will the proposed new site be integrated into and assessed via the health center’s quality improvement/assurance and risk management plans?

In responding, address the following:

  • Will it be integrated into the current QI/QA plan?

  • Are board-approved peer and chart review policies in place by which all provider(s) at the proposed site will be assessed?

  • Are risk management plans in place to assure the new site has appropriate liability coverage (e.g. non-medical/dental professional liability coverage, general liability coverage, automobile and collision coverage, fire coverage, theft coverage, etc.).



Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



Additional Considerations for Adding a Site to Scope


While the following areas are not specific
factors or criteria that will impact the CIS approval process, these are key elements that health centers should have considered or actively planned to address prior to adding a new site to scope.

A. Medical Malpractice Coverage: Your health center must develop plans for any providers that will provide services on behalf of the health center at the new site (e.g., extension of FTCA coverage, private malpractice coverage). Respond the following as applicable:

For grantees deemed under the FTCA, have you reviewed the FTCA Health Center Policy Manual or if appropriate, consulted with BPHC to assure the applicability of FTCA coverage?

The FTCA Health Center Policy Manual is available at:
http://www.bphc.hrsa.gov/policiesregulations/policies/pin201101.html For specific questions, contact the BPHC HelpLine at: 1-877-974-BPHC (2742) or Email: [email protected]. Available Monday to Friday (excluding Federal holidays), from 8:30 AM – 5:30 PM (ET), with extra hours available during high volume periods.


Yes

Not Applicable, health center is not deemed or FTCA coverage does not apply.


If you selected "Not Applicable" respond to the question below.



For health centers not deemed under the FTCA or if FTCA coverage is not applicable to the site, have you developed a plan for medical malpractice coverage?





Yes

No


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



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B. Section 340B Drug Pricing Program Participation: Health centers that participate in the 340B Drug Pricing Program are reminded that changes to the scope of project approved by BPHC do not automatically update within the 340B Program’s Database. Health centers should contact the HRSA Office of Pharmacy Affairs to determine whether any updates to the 340B Database are necessary by contacting Apexus Answers at 888-340-2787, or [email protected].

Will your health center complete all necessary 340B Program updates with the HRSA Office of Pharmacy Affairs?



Yes

Not Applicable, health center does not participate in the 340B program


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



C. Facility Requirements: Has your health center assured that any/all Federal, State and local standards/accreditation requirements of the facility where the new site will be established have been fully met (including those associated with CMS FQHC certification)?



Yes

Not Applicable


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



D. Reimbursement as a Federally Qualified Health Center (FQHC) under Medicare, Medicaid and CHIP:

Health centers are required to submit a separate Medicare enrollment application for each “permanent unit” at which they provide services. This includes units considered both “permanent sites” and “seasonal sites” under their HRSA scope of project, but not mobile vans. Health centers are also required to bill each service to Medicare using the unique Medicare Billing Number assigned to the site at which it was provided. Specifically, health centers must inform Medicare of the new site that has been added to scope by submitting a new Medicare Enrollment Application, Form 855A, to their Medicare Administrative Contractor. Form 855A is available at
https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/downloads//cms855a.pdf. For further information on the Medicare enrollment application process, review Program Assistance Letter 2011-04: Process for Becoming Eligible for Medicare Reimbursement under the FQHC Benefit available at:http://www.bphc.hrsa.gov/policiesregulations/policies/pal201104.html.

In addition, many state Medicaid programs also require all permanent and seasonal sites to enroll individually and bill using a site-specific billing number. For further information about the requirements in a state, health centers should contact their Primary Care Association or State Medicaid Agency.

Will your health center submit a separate Medicare enrollment application for the new site to the appropriate Medicare Administrative Contractor as soon as possible after HRSA’s approval of the Change in Scope, and bill for services provided at this new site using that site’s unique Medicare Billing Number?



Yes

Not Applicable


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



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Will your health center determine if a separate Medicaid enrollment application is required for your new site, and if so, submit it as soon as possible?





Yes

Not Applicable


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)



E. National Health Service Corps Program Participation: Health centers that participate in the National Health Service Corps (NHSC) are reminded that all NHSC providers must continue to work ONLY at an approved site within the health center's scope of project. Note that there may be some sites within a health center’s scope of project that are not NHSC-eligible (see the Eligibility Requirements and Qualification Factors section of the NHSC Site Reference Guide at http://nhsc.hrsa.gov/downloads/sitereference.pdf for information on eligible and non-eligible NHSC sites).

NHSC sites and participants may contact the NHSC through the Customer Service Portal (https://programportal.hrsa.gov/extranet/landing.seam) or through the Customer Care Center by calling 1-800-221-9393.

In adding this site to your scope, has your health center assessed the impact on any NHSC participants that will be asked to work at this site and advised them that they will need to seek a site reassignment with the NHSC prior to beginning work at this new site?



Yes

Not Applicable, health center does not plan to place any NHSC participants at this site.


Briefly explain your response:
Maximum paragraph(s) allowed approximately: 3 (3000 character(s) remaining)







Page 12 of 12


File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleChecklist for Adding a New Service Delivery Site - track changes
AuthorEshita Shaheed
File Modified0000-00-00
File Created2021-01-23

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