To ensure continuity of FTCA coverage, any specialty service added to the Federal scope of project must be described in the health center’s next funding application (Service Area Competition or Budget Period Renewal).  However, inclusion of a service within the Federal scope of project is, in and of itself, not enough to guarantee FTCA coverage.  FTCA deeming requirements must also be met.  For more information on policies and procedures related to FTCA deeming, please consult PAL 2008-05, “New Requirements for Deeming under the Federally Supported Health Centers Assistance Act for Calendar Year 2009” and the HRSA FTCA web site.

Also note that the definition of “provider” under the Federal scope of project may not be consistent with the definition of provider under the relevant statutory FTCA provisions.  Individuals covered by the FTCA may include others, such as certain lab and radiology technicians, as described in section 224 of the PHS Act.  Likewise, not all provider arrangements in the Federal scope of project are covered by the FTCA.  For example, volunteer providers, physicians contracted under a professional corporation or employed by other corporations, and interns/residents/medical students not employed by the health center may be included as part of the Federal scope of project, but are not covered under the FTCA.  In circumstances where the provider arrangement does not meet the criteria for FTCA coverage, health centers should ensure that the provider has sufficient alternative malpractice insurance.