IV. Definitions

A. “Scope of Project”

A health center’s scope of project includes the activities that the total approved section 330 grant-related project budget supports.⁶  Specifically, the scope of project defines the approved service sites, services, providers, service area(s) and target populations(s) which are supported (wholly or in part) under the total section 330 grant-related project budget.  A grantee’s scope of project must be consistent with applicable statutory and regulatory requirements and the mission of the health center.  A section 330-funded health center must include the provision of certain services within its scope of project, including primary health care services, referrals to providers of health-related services, patient case management services, and enabling services.⁷  Section 330-funded health centers may also provide additional health services in support of required primary health services and as appropriate for the health center population.⁸

Section 330-funded health centers may also carry out other activities (other lines of business) that are not part of their Federal scope of project and, thus, are not subject to section 330 requirements.  For example, a grantee corporation may run a day care center that is not within the scope of the federally supported project and does not use section 330 funds, personnel, or related revenue for support; therefore, it would not be subject to section 330 requirements or eligible for the benefits that extend to activities within the grantee’s scope of project.

Eligibility for Medicaid Prospective Payment System payment,⁹Medicare FQHC reimbursement, and Federal Tort Claims Act (FTCA) coverage for a health care service is contingent upon the inclusion of the service in the health center’s approved Federal scope of project.¹⁰

B. “Provider”

The term “provider” refers to individual health care professionals (including physicians, physician assistants, nurse practitioners, and certified nurse midwives) who deliver services to health center patients on behalf of the health center.  Providers assume primary responsibility for assessing the patient and documenting services in the patient’s record.  Providers include only those individuals who exercise independent judgment as to the services rendered to the patient during an encounter/visit. 

Grantees utilize a variety of mechanisms for provider staffing in order to maximize access to comprehensive, efficient, cost-effective, and quality health care. For instance, grantees may directly employ or contract with individual providers, may have arrangements with other organizations, or may utilize volunteers.¹¹ Grantees must ensure that for all contracted clinical staff or volunteers, there is a separate, written agreement.

C. “Service Site”

A service site is any location where a health center, either directly or through certain sub-recipients¹² or certain established arrangements,¹³ provides required primary health services and/or approved additional services to a defined service area or population.  Service sites are defined as locations where all of the following conditions are met:

• health center encounters/visits are generated by documenting in the patients’ record face-to-face contacts between patients and providers;
• providers exercise independent judgment in the provision of services to the patient; 
• services are provided directly by or on behalf of the grantee, whose governing board retains control and authority over the provision of the services at the location; and
• services are provided on a regularly scheduled basis (e.g., daily, weekly, first Thursday of every month).¹⁴  However, there is no minimum number of hours per week that services must be available at an individual site/location.

Administrative offices or locations that do not provide direct health care services are not service sites.

D. Primary Health Care Services

Health services related to family medicine, internal medicine, pediatrics, obstetrics and gynecology, preventive dental care, and mental health/substance abuse treatment are considered by HRSA to be “primary health care services” and are included among the health services that health centers are required to provide directly or through contracts or established arrangements under section 330.  Services provided by primary health care clinicians as part of their ordinary scope of practice are not considered “specialty services.”  This PIN addresses change in scope requests to add services other than services generally provided under these primary health care categories. 

E. “Specialty Services”

HRSA considers specialty services to be within the broad category of “additional” health services, defined in section 330 as services that are not included as required primary health care services and that are (1) necessary for the adequate support of primary health services and (2) appropriate to meet the health needs of the population served by the health center.”¹⁵  In most cases, HRSA will consider diagnostic/screening procedures, as well as some treatment procedures, to be within the scope of the health center’s section 330 project as “additional” health services.  For example, where the health center serves a population with a high prevalence of diabetes, endocrinology, podiatry, and optometry/ophthalmology services could be considered both “supportive” of primary health services for the diabetic health center patients as well as appropriate to meet the health center population’s needs.  (See additional discussion below, in section VI.A and VI. B. of this PIN.) 

F. “Specialists”

For purposes of this PIN, a specialist is considered to be an appropriately licensed and credentialed health care provider (see section VI.E. of this PIN) who has been granted appropriate specialty-specific privileges by the health center. The full range of services within a specialist’s area of expertise may or may not be within the Federal scope of project. 

issued December 18, 2008