VI. Additional Scope of Project Policy Issues

A. Scope of Project and FTCA Coverage

FTCA coverage is limited to staff and services that are documented as being within the approved scope of project and included in provider employment agreements or contracts. The requirements and other information regarding FTCA coverage and the deeming process can be found in the following PINs and PALs:

• PIN 1999-08, “ Health Centers and The Federal Tort Claims Act”
• PIN 2001-11, “Clarification of Policy for Health Centers Deemed Covered Under the Federal Tort Claims Act for Medical Malpractice”
• PIN 2001-16, “Credentialing and Privileging of Health Center Practitioners”
• PIN 2002-22, “Clarification of Bureau of Primary Care Credentialing and Privileging Policy Outlined in Policy Information Notice 2001-16”
• PIN 2002-23, “New Requirements for Deeming under the Federally Supported Health Centers Assistance Act”
• Program Assistance Letter (PAL) 99-15, “Questions and Answers on the Federal Tort Claims Act Coverage for Section 330, Deemed Grantees”
• PAL 2005-01, “Federal Tort Claims Act Policy Clarification on Coverage of Corporations under Contract with Health Centers”
• PAL 2001-25, “Procedures for General Inquiries on Federal Tort Claims Act Coverage”
• PIN 2005-19, “Federal Tort Claims Act Coverage for Deemed Consolidated Health Center Program Grantees Responding to Hurricane Katrina.”
• PIN 2007-16, “Federal Tort Claims Act (FTCA) Coverage for Health Center Program Grantees Responding to Emergencies”

These PINs and PALs can be found online at: http://bphc.hrsa.gov/policy

Questions concerning FTCA should be directed to:

FTCA Program
DHHS/ HRSA /BPHC
5600 Fishers Lane , Room 15C-26
Rockville , MD 20857
Phone: 301-594-2469
Fax: 301-594-5224
Email: HealthCenterFTCA@hrsa.gov

B. Scope of Project and FQHC Medicaid PPS or Alternative Methodology Reimbursement

After a change in scope of project that may generate a FQHC Medicaid reimbursement (e.g., PPS or APM) adjustment is approved, it is the responsibility of the grantee to notify its State Medicaid Agency of the change(s) within 90 days following HRSA approval.

Most State Medicaid Agencies require a HRSA approved change in scope project to process requests for changes in Medicaid PPS or APM (e.g., rate for new starts or rate increase/decrease). Please note that the change in scope of project for grantees discussed under this PIN is not the same as a change in the scope of services for increased/decreased reimbursement (PPS or APM) through Medicaid. The CMS and State Medicaid Agencies define the term “change in the scope of services” to refer to a mechanism for adjusting the reimbursement rate of a FQHC due to “a change in the type, intensity, duration and/or amount of services.” The HRSA approved change in scope modifies the services or sites in the grantee's scope of project for the section 330 grant. It does not approve a “change in the scope of services” for State Medicaid reimbursement purposes. Grantees should contact their State Medicaid Agency for further information about their “change in the scope of services” policy and procedures.

C. Scope of Project and Medicare FQHC Cost-Based Reimbursement

After a change in scope of project is approved, it is the responsibility of each grantee to notify its Medicare Fiscal Intermediary in a timely manner following the HRSA approval for the purposes of receiving the Medicare FQHC reimbursement rate.

In order for any new service delivery site(s) to be recognized by Medicare as a FQHC and be reimbursed the FQHC all-inclusive rate, a complete CMS 855A Form must be filed with the appropriate Medicare Fiscal Intermediary (download the CMS 855A Form (Acrobat/pdf)). For each new site added to the approved scope of project, a health center must submit the CMS 855A Form, a copy of the HRSA Notice of Grant award that includes the address for applicable site(s) being enrolled, along with the necessary accompanying documents (see page 41 of CMS-855A) to the appropriate Fiscal Intermediary. In addition, the Medicare Fiscal Intermediary should be notified within 30 days of all site address changes and changes in ownership. All other changes to enrollment should be reported within 90 days.

A unique National Provider Identifier (NPI) number is necessary for each site when completing the CMS 855A Form. The NPI is a standard unique health identifier for health care providers and is assigned by the National Plan and Provider Enumeration System (NPPES). The NPI is necessary for HIPAA standard transactions under Medicare.  Those transactions include the electronic claim, eligibility inquiry and response, claim status inquiry and response, payment and remittance advice, prior authorization/referral, and coordination of benefits transactions. Grantees are required to obtain a NPI for each service site in order to bill Medicare, Medicaid and other payers.

Complete instructions for completing the NPI application process are available on the Centers for Medicare and Medicaid Services Web page, National Provider Identifier Standard > How to Apply.
Grantees can obtain a NPI number(s) in two ways:

1) by going to the CMS National Plan and Provider Enumeration Web site to fill out an application on-line; or
2) by downloading and completing a paper application form (CMS-10114) or by calling the NPI Enumerator at 1-800-465-3203 to request a copy.

D. Scope of Project and The Section 340B Drug Pricing Program

Health centers qualify as covered entities under the section 340B Drug Pricing Program. Please note, however, that while identification as a service site within a scope of project is necessary for participation in 340B, the program has its own requirements that must be met. For information on participating in the 340B Program, please call the Office of Pharmacy Affairs at 1-800-628-6297 or 301-594-4353, or visit the HRSA Pharmacy Affairs Web site.

E. Scope of Project and Accreditation

Grantees accredited by an external accrediting body, e.g., the Joint Commission, are responsible for notifying the accrediting body of organizational changes if required by the accrediting body, as these may result in a requirement for an extension survey. Please refer to the accrediting body's policies and procedures for further guidance.

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