2002-07
DATE: December 31, 2001 DOCUMENT TITLE: Scope of Project Policy
TO: All Bureau of Primary Health Care Grantees
Attached is an update of the scope of project policy as it applies to the Bureau of Primary Health
Care (BPHC) grantees awarded funding under section 330 of the Public Health Service Act. This
Policy Information Notice (PIN) supersedes PIN 2000-04 “Scope of Project Policy,” and is
intended to clarify scope of project issues, improve consistency, and provide guidance concerning
change in scope requests. It addresses changes in scope of project that do not require additional
Federal funds. If additional Federal support will be required to implement the changes, the Center
should consider submitting an application for competitive funds.
This PIN describes the policy and procedures for requesting approval for changes in sites or
services. Although included as part of the approved scope of project, changes in target population,
service area, and providers do not need prior approval unless they are accompanied by a change in
sites or services. The following are highlights of the major changes:
_ To obtain approval for a change in service delivery sites and/or services provided, health
centers must prepare a change in scope request as outlined in this PIN. Change in scope
requests will no longer be accepted as part of the continuation grant application, but must be
submitted as a separate request.
_ References to Federally Qualified Health Center (Medicaid) cost-based reimbursement have
been replaced with references to Prospective Payment System (PPS) or other State-approved
alternative payment methodologies to reflect the change authorized in the Medicare,
Medicaid, and State Child Health Insurance Program Benefits Improvement and Protection
Act of 2000. Please note: the change in scope of project for Health Resources and Services
Administration grantees is not the same as a change in scope of services for increased
reimbursement through the PPS.
_ There is no process for retroactive approval of change in scope requests. If approved, the
effective date is the date the request is received by the BPHC. However, if not subsequently
approved, health centers are at risk for the specific site/service during the time period prior to
notification of disapproval. Please plan accordingly and submit change in scope requests far
enough in advance to allow for adequate review time.
_ Electronic submission is the preferred method for submitting a change of scope request.
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As this revised scope of project policy is implemented, the BPHC plans to obtain feedback and
make revisions when necessary. If you have questions regarding the scope of project policy or
the information presented in this document, please contact your project officer identified on the
Notice of Grant Award. The BPHC headquarters and field staff should direct questions and
concerns to Barbara Bailey at 301-594-4315.
Marilyn Hughes Gaston, M.D.
Director, Bureau of Primary Health Care
Attachments
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SCOPE OF PROJECT POLICY
I. INTRODUCTION
The mission of the Bureau of Primary Health Care (BPHC) is to increase access to quality
primary health care services and reduce health disparities for underserved and vulnerable
populations. As the health care marketplace continues to change and foster new ways of
delivering health services, it is vital that BPHC-supported health centers adapt to the changing
marketplaces while maintaining their commitment to the philosophy and intent of this mission.
Because of the importance of the scope of project concept, it is crucial that health centers request
approval for changes of scope in the areas of sites and services, and update the BPHC regarding
any other changes to the scope of project prior to occurrence. This Policy Information Notice
(PIN) supersedes PIN 2000-04 “Scope of Project Policy” and outlines the process for requesting
approval of changes in the current scope of project.
II. APPLICABILITY
This PIN applies to all BPHC health service delivery grants awarded under section 330 of the
Public Health Service (PHS) Act, including the Community Health Center, Migrant Health
Center, Health Care for the Homeless, Public Housing Primary Care, and Healthy Schools
Healthy Communities Programs, collectively referred to as “health centers.” Section 330
outlines the services that health centers must provide, including primary health services, referrals
to providers of health-related services, patient case management services, enabling services,
education, and additional health services as appropriate for the health center population. Based
on this legislation, PIN 98-23, “Health Center Program Expectations,” describes the program
expectations for BPHC programs. A health center’s scope of project should be consistent with
these program expectations, as well as with the missions of the health center and BPHC.
III. IMPORTANCE OF SCOPE OF PROJECT
The scope of project is a description of the health center’s project, categorized by five core
elements: services, sites, providers, target population, and service area(s). The scope of project:
_ Stipulates what the total approved grant-related project budget supports, specifically defining
the services, sites, providers, target population, and service area for which grant funds may be
used, in whole or in part. This total project budget includes program income and other nonsection
330 funds.
_ Defines broadly the scope of coverage (subject to exceptions) of the Federal Tort Claims Act
(FTCA) program that provides medical malpractice coverage for deemed health centers and
most individual employees (see PIN 99-08 “Health Centers and The Federal Tort Claims
Act,” PIN 2001-11 “Clarification of Policy for Health Centers Deemed Covered Under the
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Federal Tort Claims Act for Medical Malpractice,” and Program Assistance Letter (PAL) 99-
15 “Questions and Answers on the Federal Tort Claims Act Coverage for Section 330,
Deemed Grantees”);
_ Defines for the section 340B Drug Pricing Program, the necessary site information enabling
covered entities to purchase discounted drugs for patients;
_ Defines the approved service delivery sites and services necessary for State Medicaid Offices
to calculate payment rates under the Prospective Payment System (PPS) or other Stateapproved
alternative payment methodology (see PAL 2001-09 Department of Health and
Human Services Fiscal Year 2001 Appropriations, Other Legislation, and Regulation
Issuances) and subsequent information posted on www.bphc.hrsa.gov; and
_ Defines the approved service delivery sites necessary for the Centers for Medicare and
Medicaid Services (CMS) to determine a health center’s eligibility for Federally Qualified
Health Center (FQHC) Medicare cost-based reimbursement.
An approved scope of project is often part of a larger health care delivery system and, as such,
needs to be distinctly defined within that context. The BPHC-supported health centers may have
other activities that are not part of their scope of project, referred to as Other Lines of Business
(OLB) and, thus, are not subject to section 330 requirements and expectations. It is important to
note that for activities that are not part of the scope of project, the health center is not entitled to
certain benefits, i.e., utilization of section 330 funds, Medicaid PPS and FQHC payments and
Medicare FQHC reimbursements, FTCA coverage, and Drug Pricing benefits. In addition, there
must be sufficient revenue from the OLB to support all direct costs of the activity and a
proportionate share of overhead to ensure that section 330 funds and other grant-supported
resources are not inappropriately used to support costs outside the approved scope of project.
IV. FIVE CORE ELEMENTS OF SCOPE OF PROJECT
Five core elements constitute scope of project and address these fundamental questions:
· Where will services be provided (sites)?
· What services will be provided (services)?
· Who will provide the services (providers)?
· What area will the project serve (service area)?
· Who will the project serve (target population)?
A. Sites
A site is any place where a health center provides services to a defined geographic service
area or population on a regular, scheduled basis (e.g., daily, weekly, or monthly) regardless of
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the number of hours per week, and does so as part of the project. Sites are where the health
center generates encounters by documenting face-to-face contacts between patients and
providers who exercise independent judgment in the provision of services to the individual.
They can include, but are not limited to, health care facilities, schools, migrant camps,
homeless shelters, and mobile medical vans where health care services are provided. Those
sites at which the health center regularly provides care must be listed in Exhibit B (sites) of
the Single Grant Application to be considered for inclusion in the scope of project; however,
for limited service arrangements with multiple locations of a certain type, health centers may
list the type of location in Exhibit B rather than each individual location. For example, if a
health center provides immunizations once a month at 15 different day care centers, the
individual day care centers need not be listed as sites; however, the category “day care
center” should be listed in Exhibit B, and the activity should be described in the narrative,
“Section I, part 5 Project Summary” for project period renewals and “Section II, part 4
Project Update” for budget period renewals.
Although the locations where clinicians and project staff go from time-to-time to seek out,
engage and serve persons eligible for the project’s services are covered under the scope of the
project, compiling an exhaustive list of such sites is impractical and is not required to define
the approved scope of project. For example, locations for off-site activities required by the
health center and documented as part of the employment agreement or contract between
the health center and the provider (e.g., health center physicians providing coverage at the
hospital emergency room or participating in hospital call for unassigned patients) do not need
to be listed as sites, but may be included in scope of project. Also, locations where the only
services delivered do not generate encounters (i.e., filling prescriptions, taking X-rays,
performing street outreach or providing health education, etc.) need not be listed as sites, but
should be described in the scope of project and included in the annual grant application, as
they contribute to the provision of comprehensive primary care services. Administrative
offices that do not provide services are not considered service sites; therefore, any changes in
location of administrative offices do not require approval.
B. Services
The services provided by a health center, either directly or by referral, are identified in
Exhibit B (services) of the Single Grant Application. Services are reported in aggregate for
the total Center, not on a site-by-site basis. In general, a change in services provided will be
viewed from the perspective of the grantee, not the individual site, as it has long been the
policy of the BPHC that not all services must be available at every grantee site. Rather, the
patient must have reasonable access to the full complement of services offered by the center
as a whole.
In addition to the direct provision of services, health centers may have a variety of
arrangements for providing services through contractors or other referral arrangements. The
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scope of project should identify situations where the health center has made formal
arrangements (i.e., a written agreement or ability to document the service in the patient
record) to ensure availability of comprehensive services to its patients. Referral
arrangements are considered part of scope of project if the health center makes the referral
and receives feedback to enable appropriate follow-up. Note: FTCA and Drug Pricing
coverage does not extend to all such arrangements. Health centers should refer to PINs 99-08
“Health Centers and The Federal Tort Claims Act” and PIN 2001-11 “Clarification of Policy
for Health Centers Deemed Covered Under the Federal Tort Claims Act for Medical
Malpractice,” to clarify whether an arrangement is covered by FTCA, and to Federal
Register, Vol. 61, No. 207, page 55157-8, “Patient and Entity Eligibility” for clarification of
the Drug Pricing benefit for referrals.
Provision of non-primary care services must be based on the needs of the community and the
capacity of the health center to provide those services. Health centers are encouraged to
thoroughly investigate the costs, benefits, and risks before providing these services.
C. Providers
Providers are individual health care professionals who deliver services on behalf of the health
center on a regularly scheduled basis. They assume primary responsibility for assessing the
patient and documenting services in the patient’s record. Providers include only individuals
who exercise independent judgment as to the services rendered to the patient during an
encounter. Moonlighting, defined as engaging in professional activities outside of the
provider’s employment responsibilities to the primary employer (health center), is not
considered part of the scope of project.
Complementary and alternative medicine providers may be included in the scope of project
and be covered under FTCA if the provider is practicing in compliance with State law and
regulations.
Please note that the BPHC definition of “provider” may not be consistent with those
providers who are covered under FTCA. Individuals covered by FTCA may include others,
such as lab and radiology technicians, as described in section 224 of the PHS Act. Likewise,
not all provider arrangements in the scope of project are covered by FTCA. For example,
volunteer providers, physicians contracted under a professional corporation or employed by
another corporation, physicians acting as Chief Medical Officers of a network,
interns/residents/medical students not employed by the health center, and health center
physicians supervising non-health center employees (except to fulfill on-call or contractual
requirements, including subrecipient oversight) may be included as part of scope of project,
but are not covered under FTCA.
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D. Service Area and Target Population
The service area is the geographic area that is served by the health center. The target
population is the medically underserved community or special population to be served by the
health center. The target population must be represented on the health center Board of
Directors.
Health centers are expected to collaborate with other entities who provide primary care
services in the same service area and/or to the same target population to ensure that their
activities are complementary and collaborative. To this end, health centers should be able to
document efforts to work positively with other entities in the area to be served.
V. POLICY FOR CHANGE IN SCOPE OF PROJECT
In response to the changing environment, many health centers have undertaken changes to their
scope of project, such as adding new sites and/or services, to improve their financial viability;
however, these changes in scope of project may pose high risks to the health center. Approval is
contingent on a demonstration of projected revenue and expenses showing break-even (worst
case scenario) or the potential for generating a surplus. A complete financial analysis of the
impact of adding a site/service is imperative to ensure long-term viability. Because unforeseen
events may occur, making original projections inaccurate, health centers should continually
monitor the progress of their new site and/or service and be prepared to take remedial action
should revenues fail to meet or exceed expenses. Surpluses must be reinvested in activities that
further the objectives of the health center project, consistent with and not specifically prohibited
by section 330. Any request for change in scope of project must be approved by the Board of
Directors of the health center.
This PIN addresses those changes in scope of project that do not involve additional section 330
funding at the time of the request.1 Once approved, however, existing section 330 funding may
be used for new sites and services added to the scope of project.
A. Required Approval for Change of Sites (adding, dropping, or relocating) and
Change of Services (adding or dropping)
Based on regulations outlined in Title 45, Parts 74 and 92 of the Code of Federal
Regulations and the PHS Grants Policy Statement, health centers must obtain prior
approval for significant changes in the approved scope of project (i.e., changes in sites and
services). An increase or decrease in the number of sites, certain relocations of sites
previously approved in Exhibit B (service sites) of the Single Grant Application, and
1 If additional section 330 funds are necessary to make the project viable, the health center should submit an
application for competitive funding opportunities rather than a change in scope.
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adding or dropping a service approved in Exhibit B (current services provided) of the
Single Grant Application, are considered significant changes in the scope of project and
therefore require prior approval from BPHC. However, the relocation of a site that does
not impact the budget, the services provided, the number of patients served, or the number
and type of providers available does not require prior approval and, therefore, the health
center does not need to submit a change in scope request for such relocation. For example,
the relocation of a site from an inadequate building to a new, similar-sized building nearby
typically will not require prior approval. However, if the relocation involves a much larger
building that will serve more patients, offer more services, and have budgetary impact, such
a change will require prior approval.
Although prior approval is not required for some relocations, centers should, at a minimum,
submit a revised Exhibit B from the Single Grant Application and a cover letter describing
the relocation, the square footage involved, cost differences due to change in facility,
staffing and patients seen at the address included in Section B – Process for Change in
Scope to ensure continued FTCA and Drug Pricing coverage.
There is no requirement to obtain prior approval for changes affecting target population,
providers, and service area that are not linked with changes in sites or services. For
example, if the health center has been providing mental health services with a social worker
and decides to add a psychologist, there is no change in the services being provided (mental
health) and, therefore, the health center does not need to request prior approval if there is no
significant impact on the budget. Similarly, the issue of adding a service currently provided
at one site to another existing site may require the submission of additional information to
ensure coverage from FQHC, FTCA, Drug Pricing benefits, but should not require a change
in scope request if additional funds will not be necessary. Changes in providers, target
population, and service area should be noted in the continuation application, and health
centers should continue to keep their project officer apprised by phone and in writing of
these changes prior to occurrence. Any request for a change in sites and/or services will be
reviewed to determine if it 1) meets the "no additional section 330 funding" criterion; 2)
does not shift resources away from providing services for underserved and vulnerable
populations; 3) furthers the mission of the health center by increasing or maintaining access
and improving or maintaining quality of care for underserved and vulnerable populations;
4) is fully consistent with section 330 legislation and BPHC program expectations
including appropriate Board representation for changes in sites; 5) does not eliminate or
reduce access to a required service; 6) does not result in the diminution of the level or
quality of health services currently provided to the target population; and 7) continues to
serve a Medically Underserved Area (MUA) or Medically Underserved Population (MUP)
(for projects required to serve a MUA or MUP). Please note that the site does not have to
be located in an MUA to serve it.
B. Process for Change in Scope of Project
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To obtain approval for a change in sites and/or services, health centers must prepare a
change in scope request, as outlined in the following two sections of this PIN. Change in
scope requests will no longer be accepted as part of the continuation grant application, but
may be submitted at any time during the year. To expedite the process an email account
specific for change in scope requests has been established. Section 330 grantees should
email their complete change in scope request to bphcscope@hrsa.gov and send a signed
original to the Office of Grants Management at 4350 East-West Highway, 11th Floor,
Bethesda, Maryland 20814. A courtesy copy should also be forwarded to your project
officer in the Field Office.
Health centers should consult with their project officer in the Field Office as soon as they
begin to consider making changes to their scope of project. Ideally, health centers should
anticipate most changes and submit a request for approval at least 60-days before
implementing the anticipated change. The BPHC does recognize that there are
circumstances where submitting a change in scope request early may not be possible;
however, the goal is to minimize these occurrences through strategic planning. The
BPHC does not have a process for retroactive approval; therefore, late submission of a
change in scope request could jeopardize Medicaid PPS and Medicare FQHC
reimbursements, FTCA coverage, and Drug Pricing benefits for the specific site/service
during the time period prior to action being taken. The date of receipt of a complete
application will be considered the effective date of benefits coverage for any approved
changes.
For those change in scope requests that are incomplete, the BPHC aims to notify the
health center within 10-days of receipt of the request, asking for the missing information
to be provided within 30-days. If the missing information is not provided by the end of
30 days, the request will be denied and returned to the center. The BPHC’s goal is to
respond to health centers with a Notice of Grant Award (NGA) indicating approval or a
letter indicating disapproval within 60-days of receipt of the complete request, assuming
the health center submits all the information according to the process outlined in
this PIN. Due to the varying complexity of requests, it may be necessary, in some cases,
to extend the process if additional review, such as an on-site consultation, is necessary.
In those cases, the health center will be notified within the 60-day review period of any
potential delays in processing requests. The BPHC strongly encourages health centers to
plan accordingly.
Although health centers must request approval for changes in scope separate from their
continuation grant applications, it is still very important for health centers to fully
describe their scope of project for all five core elements in their continuation grant
application.
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C. Format for Requesting the Addition of a Site/Service or Relocation of a Site
For adding a site/service or relocating a site, the following information should be
provided:
_ Cover Page (Attachment A of this PIN)
_ Completed Exhibit B (Current Services Provided and Service Sites) of the Single
Grant Application.
_ One-year budget specific for the change, showing the projected number of encounters,
payer mix, revenue and expense projections, sources of support, and sustainability. If
any of the sources of funding are not projected to continue beyond an initial period of
time (i.e., beyond the first year of the project), please describe what sources will
support the change in scope in the future. The revenue and expense projections must
be at a level of detail that clearly shows no additional section 330 funding is required
for the change. For an example of calculations to be included in a revenue projection,
please refer to the Single Grant Application Form 3 entitled “Income Analysis
Format.”
_ One-year total budget (for the entire scope of project including the requested change),
showing the projected total number of encounters, payer mix, and revenue and
expense projections. Again, the revenue and expense projections must be at a level of
detail that clearly shows no additional section 330 funding is required for the change.
_ Completed and signed Change in Scope Assurances Checklist (Attachment B of this
PIN)
_ A brief narrative (maximum of 6 pages for adding or relocating a site; maximum of 3
pages for adding a service) describing the change in scope that is being proposed and
addressing the following questions:
1. Why is the change in scope being proposed? Include the following information:
a. The latest community needs assessment that illustrates a need for the new
site/service in the community.
b. If no needs assessment was completed, an explanation of how the need for the
new site/service was determined.
c. The impact of the change on the total organization, including a description of
the service delivery system and how the appropriateness and quality of care
are maintained for the new site or service.
2. If the target population for the new site/service is different from that currently served
by the health center, what is the target population of the new site/service? Include the
following information:
a. Number of patients expected to be seen annually at the new site or expected to
utilize the service.
b. Information demonstrating the need of the target population.
c. Percentage of individuals below 200 percent of the Federal Poverty
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Level.
d. Percentage of uninsured individuals.
e. Health disparities present in the target population.
f. Any additional information that will document the need, such as
unemployment rate, percentage of minority/special populations, ratio of
primary care physicians to population, etc.).
3. If the service area of the new site/service is different from that currently served by
the health center, what is the service area for the new site/service? Include the
following information:
a. List of census tracts, counties, minor civil divisions, etc., in the new service
area.
b. List of other existing entities who provide primary care services to the same
target population and/or in the same geographic service area. Highlight the
safety net providers i.e., other BPHC-supported health centers, rural health
clinics, FQHC Look-Alikes, and other related entities that are serving the
same geographic area or target population.
c. Description of coordinated/collaborative efforts with these entities.
d. Letters of support from safety net providers in the area.
e. Description of Board representation from the new service area.
4. For adding or relocating a site: How will the new site be staffed, and what services
will be provided? Include the following information:
a. Number and types of providers.
b. If not all required primary care services that the health center offers its patients
at other sites are being provided, how will access to these services be assured?
For example, if the new site will provide only dental or mental health services,
how will access to comprehensive services be assured?
5. For adding a service:
a. If it is a specialty or non-primary care service, how does it complement
primary care services and the health care needs of the users and community?
b. If it has traditionally been the financial responsibility of a local, county, or
State government, why is the health center assuming responsibility for the
service?
D. Format for Requesting the Reduction of a Site/Service
For dropping a site or service, the following information should be provided:
_ Cover Page (Attachment A of this PIN)
_ Completed Exhibit B (Current Services Provided and Service Sites) of the Single
Grant Application.
_ One-year budget specific for the change, showing the impact on payer mix, revenue
projections, and expense projections.
_ One-year total budget (for the entire scope of project including the requested change),
showing the projected number of encounters, payer mix, and revenue and expense
projections.
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_ Completed and signed Change in Scope Assurances Checklist (Attachment C of this
PIN)
_ A brief narrative (maximum of three pages for dropping a site; maximum of two
pages for dropping a service) describing the change in scope that is being proposed
and addressing the following questions:
1. Why is the reduction in site/service being proposed?
2. Describe the target population currently served by the site/service. Include the
following information:
a. Number of annual users
b. Number of annual patient encounters
c. Describe any other access to health care issues of the population (i.e., number
of uninsured and low-income individuals, health disparities, etc.).
3. What is the impact on this target population from dropping the site/service?
4. Describe how access to care has been assured for patients currently served by the
site/service.
a. Include a list of other providers in the area who can deliver services to the
Population and the contact made with them.
b. What effect does dropping the site/service have on the required services
provided? Please address how the appropriateness and quality of care will be
maintained.
VI. SCOPE OF PROJECT POLICY ISSUES
A. Scope of Project and FTCA Coverage
The FTCA coverage is applicable only to staff and services that are documented as being
within the scope of the approved project. Therefore, it is critically important that requests
for approval of changes in sites and/or services be submitted to BPHC and that the
approved changes be included as part of the described scope of project in the health
center's next continuation application. The complete requirements for FTCA coverage
and the deeming process are outlined in PINs 99-08 and 2001-11 and include additional
requirements beyond maintaining an updated scope of project. Questions concerning
FTCA should be directed to the FTCA Coordinator in your Field Office.
B. Scope of Project and FQHC Medicaid PPS or Alternative Methodology
Reimbursement
_ After a change in scope of project is approved by BPHC, it is the responsibility of
each health center to notify its State Medicaid office of any changes pertaining to sites
and services. Most States rely on the approved scope of project to make FQHC
Medicaid PPS or alternative payment methodology decisions. Please note the change
in scope of project for Health Resources and Services Administration grantees is not
the same as a change in scope of services for increased reimbursement through the
PPS.
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C. Scope of Project and FQHC Medicare Cost-Based Reimbursement
After a change in scope of project is approved by BPHC, it is the responsibility of each
health center to notify its CMS Regional Office regarding any changes in sites for the
purposes of receiving FQHC Medicare cost-based reimbursement.
D. Scope of Project and the Section 340B Drug Pricing Program
Health centers qualify as covered entities under the section 340B Drug Pricing Program.
However, only “patients” being served within a health center’s scope of project are
eligible for discounted drug purchases. An individual is considered a “patient” if:
_ the health center has established a relationship with the individual (i.e., maintains
records of the individual’s health care);
_ the individual receives health care services from a health care professional who is
either employed by the health center or provides health care under contractual or other
arrangements such that the responsibility for the care provided remains with the
health center; and
_ the individual receives a health care service or range of services from the health center
that is consistent with the service or range of services for which grant funding is
awarded.
_ the individual will not be considered a patient of the health center for purposes of
section 340B if the only health service received from the health center is the
dispensing of a drug.
For further information regarding this program, please call the Office of Pharmacy Affairs
at 1-800-628-6297 or 301-594-4353.
E. Scope of Project and Accreditation of Health Centers
Health centers accredited by the Joint Commission on Accreditation of Healthcare
Organizations (JCAHO) are responsible for notifying JCAHO of organizational changes,
as these may result in a requirement for an extension survey. Specific information can be
found in the JCAHO Official Accreditation Policies and Procedures chapter of the current
Comprehensive Accreditation Manual for Ambulatory Care.
For those health centers accredited by other organizations, please refer to the accrediting
body’s policies and procedures.
F. Contact Information
If you have any questions regarding the scope of project policy or the process for
requesting approval of changes in scope, please contact your project officer identified on
the NGA.
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ATTACHMENT A: COVER PAGE FOR CHANGE IN SCOPE REQUESTS
HEALTH CENTER NAME: ___________________________________________________________
ADDRESS: __________________________________________________________________________
PHONE: _____________________________FAX: __________________________________________
EMAIL: ______________________________FIELD OFFICE: _______________________
GRANT NUMBER (See Block 4 of NGA):_________________________________________________
CONTACT PERSON
NAME:___________________________________________________________
PHONE NUMBER:_____________________EMAIL ADDRESS:_____________________________
TYPE OF CHANGE IN SCOPE REQUEST & COMPLETED INFORMATION
___ Adding a Service
Exhibit B of the Single Grant Application
One-year budget specific for the change
One-year total budget (for the entire scope of project)
Change in Scope Assurances Checklist (Attachment B)
Narrative addressing questions outlined in Section V of the PIN
___ Adding a Site
Exhibit B of the Single Grant Application
One-year budget specific for the change
One-year total budget (for the entire scope of project)
Change in Scope Assurances Checklist (Attachment B)
Narrative addressing questions outlined in Section V of the PIN
___ Relocating a Site
Exhibit B of the Single Grant Application
One-year budget specific for the change
One-year total budget (for the entire scope of project)
Change in Scope Assurances Checklist (Attachment B)
Narrative addressing questions outlined in Section V of the PIN
___ Deleting a Service
Exhibit B of the Single Grant Application
One-year budget specific for the change
One-year total budget (for the entire scope of project)
Change in Scope Assurances Checklist (Attachment C)
Narrative addressing questions outlined in Section V of the PIN
___ Deleting a Site
Exhibit B of the Single Grant Application
One-year budget specific for the change
One-year total budget (for the entire scope of project)
Change in Scope Assurances Checklist (Attachment C)
Narrative addressing questions outlined in Section V of the PIN
Send all requests via email to bphcscope@hrsa.gov with the original signed copy to the Office of
Grants Management, 4350 East West Highway, Bethesda, Maryland 20814, with a courtesy copy to
your project officer in the Field Office.
ATTACHMENT B: CHANGE IN SCOPE ASSURANCES CHECKLIST
BPHC Policy Information Notice 2002-07
16
(For Requesting the Addition of a Site/Service or Relocation of a Site)
1. A preliminary consultation with the Field Office (FO) program contact was made.
_ Yes _ No
Documentation: Contacted______________________(FO) on_________________(date)
2. The Board has approved the change in scope.
_ Yes _ No
Documentation: Board minutes dated_______________________________________
3. The health center organization will continue to serve a Medically Underserved Area or
Medically Underserved Population.
_ Yes _ No
Documentation: Institutional file MUA and MUP Designation dated_________________
4. The change in scope will maintain access to primary and/or preventive care for the
underserved population.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
5. The change in scope will maintain the appropriateness of care, quality of care, and outcomes.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
6. The change in scope is part of a comprehensive primary health care system.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
7. The health center will offer discounts to individuals with incomes below 200 percent of
poverty level at the new site or for the new service, as applicable, and services will be
provided regardless of patients’ ability to pay.
_ Yes _ No
Documentation: On-site file Schedule of Discounts dated_________________________
8. The change in scope will not reduce the scope of primary care services offered to the target
population or the total number of patients seen.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
9. No additional section 330 funding is required to support the new site/service.
_ Yes _ No
Documentation: Budget as outlined in Section V of this PIN.
10. The health center organization is financially stable (i.e., not on a restricted drawdown,
experiencing an operating deficit, or operating under a recovery plan).
_ Yes _ No
Documentation: Budget as outlined in Section V of this PIN.
BPHC Policy Information Notice 2002-07
17
11. The change in scope complies with section 330, the implementing rules, and program
expectations outlined in PIN 98-23. For example:
A. New site/service is integrated into the health center’s risk management program
B. New site/service is integrated into the health center’s quality assurance plan
C. New site/service is integrated into the health center’s management structure
D. Providers will undergo a process of credentialing and/or privileging
_ Yes _ No
Documentation: On site files dated_________________________________________________
12. If added or relocated sites have a different service area and/or target population than those
already being served, board representation will be modified to represent users of those added
or relocated sites.
_ Yes _ No _ N/A
Documentation: Board minutes dated_________________________________________
13. If added or relocated sites are serving the same target population and/or the same service area
as another FQHC, efforts have been made to collaborate on this specific change.
_ Yes _ No _ N/A
Documentation: Justification addressed in narrative on page________________________
14. If the health center is not covered under FTCA, the health center will make arrangements for
malpractice coverage with a private insurer.
_ Yes _ No _ N/A
15. If the health center participates in the section 340B Drug Pricing Program, the health center
will notify the Office of Pharmacy Affairs regarding any approved site changes.
_ Yes _ No _ N/A
16. If the health center receives PPS-related reimbursements from Medicaid by virtue of being a
FQHC, the health center will notify the State Medicaid office regarding any approved site and
service changes.
_ Yes _ No _ N/A
17. If the health center receives cost-based reimbursements from Medicare by virtue of being a
FQHC, the health center will notify the CMS Regional Office regarding any approved site
changes.
_ Yes _ No _ N/A
18. If the health center is currently accredited, the health center will notify the accrediting agency
regarding any approved changes, in accordance with the accrediting body’s policies and
procedures.
_ Yes _ No _ N/A
*If you answered “No” to any of the assurances, briefly explain and discuss any relevant factors
(attach additional pages, if necessary):
BPHC Policy Information Notice 2002-07
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To the best of my knowledge, I assure that the above information is true and correct.
Signature: _______________________________________________________
Name: ____________________________________________________________
Date: ____________________________________________________________
BPHC Policy Information Notice 2002-07
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ATTACHMENT C: CHANGE IN SCOPE ASSURANCES CHECKLIST
(For Requesting the Reduction of a Site/Service)
1. A preliminary consultation with the Field Office project officer was made.
_ Yes _ No
Documentation: Contacted______________________(FO) on_________________(date)
2. The Board has approved the change in scope.
_ Yes _ No
Documentation: Board minutes dated_______________________________________
3. The health center organization will continue to serve a Medically Underserved Area or
Medically Underserved Population.
_ Yes _ No
Documentation: Institutional file MUA and MUP Designation dated_________________
4. The change in scope will maintain access to primary and/or preventive care for the
underserved population.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
5. The change in scope will maintain the appropriateness of care, quality of care, and outcomes.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
6. Efforts have been made to contact other providers in the area to assure access to care for
patients currently service by the site/service.
_ Yes _ No
Documentation: Addressed in narrative of request on Page________________________
7. The change in scope complies with section 330, the implementing rules, and program
expectations outlined in PIN 98-23.
_ Yes _ No
**If you answered “No” to any of the assurances, briefly explain any relevant factors.
To the best of my knowledge, I assure that the above information is true and correct.
Signature: __________________________________________________________________
Name: ___________________________________________________________________________________
Date: ______________________________________________________________________