COVID-19 Frequently Asked Questions (FAQs)

To date, HRSA has awarded more than $2 billion to support HRSA-funded health centers and Health Center Program look-alikes in responding to COVID-19:

• On Tuesday, March 24, HRSA announced the release of $100 million in funding provided by the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (PDF - 292 KB) (activity code H8C).
• On Wednesday, April 8, HRSA announced the release of more than $1.3 billion in funding provided by the Coronavirus Aid, Relief, and Economic Security (CARES) Act (PDF - 1 MB) (activity code H8D).
• On Thursday, May 7, HRSA announced the release of approximately $583 million in Expanding Capacity for Coronavirus Testing (ECT) funding provided by the Paycheck Protection Program and Health Care Enhancement Act  (PDF - 287 KB) (activity code H8E).
• On Thursday, July 9, HRSA announced the release of more than $17 million in Look-Alikes: Expanding Capacity for Coronavirus Testing (LAL ECT) funding provided by the Paycheck Protection Program and Health Care Enhancement Act (PDF - 287 KB).

HRSA has also awarded nearly $12.9 million to support training and technical assistance to enhance health centers’ COVID-19 response:

• More than $5.8 million to 52 Primary Care Associations.
• Nearly $2.5 million to 21 National Training and Technical Assistance Partners.
• More than $4.5 million to 49 Health Center Controlled Networks.

For additional information, see the Coronavirus-Related Funding Frequently Asked Questions.

(Updated: 7/28/2020)

Health centers may be eligible for relief through several provisions of the CARES Act:

• The Small Business Administration's Paycheck Protection Program provided loans up to $10 million for non-profits with fewer than 500 employees to help prevent workers from losing their jobs and small businesses from shutting down due to economic losses caused by the COVID-19 public health emergency. Note that the Paycheck Protection Program closed August 8, 2020.
• The Small Business Administration's Economic Injury Disaster Loan Program provides financial assistance to small businesses or private, non-profit organizations that suffer substantial economic injury as a result of COVID-19, regardless of whether the applicant sustained physical damage. Organizations are eligible for grants up to $10,000 and loans up to $2 million.
• The CARES Act Provider Relief Fund supports health care-related expenses or lost revenue attributable to COVID-19 and ensures uninsured Americans can get testing and treatment for COVID-19. For answers to specific questions, providers should call the toll-free Provider Support Line at 866-569-3522.
• HHS is also providing claims reimbursement to health care providers who have conducted COVID-19 testing or provided treatment for uninsured individuals with a COVID-19 diagnosis on or after February 4, 2020, through the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program. Providers can begin the process to file claims for reimbursement at the HRSA COVID-19 Uninsured Program Portal . For general information about this program, view the Frequently Asked Questions. For answers to specific questions, providers should call the toll-free Provider Support Line at 866-569-3522. See additional information in the questions below.
• For information on how workers and employers will benefit from the protections and relief offered by the Emergency Paid Sick Leave Act and Emergency Family and Medical Leave Expansion Act, both part of the Families First Coronavirus Response Act, review updated information from the Department of Labor.

The following additional resources may also be helpful for health centers:

• The National Association of Community Health Centers (NACHC) has summarized new federal programs that that may assist health centers  in addressing cash flow and payroll concerns created by the COVID-19 pandemic.
• The Small Business Administration has information on Coronavirus (COVID-19): Small Business Guidance & Loan Resources.

• Capital Link has COVID-19 funding sources and financing-related resources and tools .

This is not an exhaustive list, and health centers should review each funding opportunity to determine program eligibility and requirements. Please note that HRSA award recipients may not use Health Center Program grant funds for costs that are reimbursed or compensated by other federal or state programs that provide for such benefits. Health centers are also encouraged to reach out to other federal, state, and local partners for additional information and resources.

(Updated: 12/14/2020)

The CARES Act Provider Relief Fund supports health care-related expenses or lost revenue attributable to COVID-19 and ensures uninsured Americans can get testing and treatment for COVID-19. See the CARES Act Provider Relief Fund webpage for details about current and future allocations. For answers to specific questions, providers should call the toll-free Provider Support Line at 866-569-3522.

(Updated: 6/24/2020)

HHS will provide claims reimbursement to health care providers who have conducted COVID-19 testing or provided treatment for uninsured individuals with a COVID-19 diagnosis on or after February 4, 2020. Providers can begin the process to file claims for reimbursement at the HRSA COVID-19 Uninsured Program Portal .

For general information about this program, view the HRSA webpage or Frequently Asked Questions. For answers to specific questions, providers should call the toll-free Provider Support Line at 866-569-3522.

(Added: 5/6/2020)

In accordance with current Health Center Program billing and collections requirements, health centers must make every reasonable effort to collect appropriate reimbursement for their costs, including billing Medicare, Medicaid, CHIP, and other public and private insurance or assistance programs, as applicable. Health centers must apply their sliding fee discount schedules consistent with their established policies and procedures. For costs associated with testing uninsured individuals for COVID-19 or treating uninsured individuals with a positive COVID-19 diagnosis that are not reimbursed by other programs, health centers may—and HRSA encourages them to—submit claims for reimbursement to the HRSA COVID-19 Uninsured Program.

To participate in the HRSA COVID-19 Uninsured Program, providers must attest that they have checked for health care coverage eligibility and confirmed that the patient is uninsured. Specifically, providers must verify that the patient did not have coverage through an individual or employer-sponsored plan, a federal health care program, or the Federal Employee Health Benefits Program at the time services were rendered, and that no other payer will reimburse them for COVID-19 testing and/or care for that patient.

Health centers that submit claims for reimbursement to the HRSA COVID-19 Uninsured Program are responsible for adhering to all applicable HRSA COVID-19 Uninsured Program requirements, including certain prohibitions against balance billing and reporting requirements. For general information about the HRSA COVID-19 Uninsured Program, view the HRSA webpage or Frequently Asked Questions. For answers to specific questions about the HRSA COVID-19 Uninsured Program, providers should call the toll-free Provider Support Line at 866-569-3522.

Health centers are also reminded that, in accordance with Health Center Program requirements, they must operate in a manner such that no patient shall be denied service, including services related to COVID-19 testing or treatment, due to an individual’s inability to pay (Health Center Program Compliance Manual Chapter 16: Billing and Collections). For additional information, see the related question “Can health centers charge patients for COVID-19 related testing and treatment?” in the Program Oversight and Monitoring section of this FAQ.

(Added: 8/20/2020)

Yes. Health center awardees have flexibility in the use of the equipment and supplies purchased with previously awarded supplemental funding to support other in-scope activities at their health center. The requirements for use and disposition of equipment and supplies acquired under the Health Center Program award are governed by the Uniform Administrative Requirements at 45 CFR §75.320 and §75.321.

(Added: 3/24/2020)

FY 2021 Health Center SACs:

• 2-year or 3-year project period: To provide flexibility during the COVID-19 pandemic response, HRSA is extending the project periods of the majority of health centers scheduled to complete a SAC in FY 2021. Health centers whose current 2-year or 3-year project period ends in FY 2021 will receive a 12-month extension with funds and will complete a Budget Period Progress Report (BPR) rather than a SAC in FY 2021.
• 1-year project period: Based on statutory requirements, health centers in a current 1-year project period will still complete an FY 2021 SAC. HRSA released the FY 2021 SAC Notice of Funding Opportunity in mid-June, approximately one month later than usual.

FY 2021 Look-Alike RDs:

• 3-year designation period: Look-alikes with a current 3-year designation period will receive a 12-month extension and complete an FY 2021 Annual Certification (AC) rather than an RD.
• 1-year designation period: Look-alikes with a current 1-year designation period will still complete an FY 2021 RD. HRSA expects to release the FY 2021 RD instructions in early July, approximately one month later than usual.

Please submit any questions via the BPHC Contact Form .

(Added: 6/25/2020)

Given the impacts of COVID-19 on health center operations—and consistent with past practice—HRSA does not anticipate reducing FY 2022 SAC funding for health centers that do not achieve previously established patient targets.

(Updated: 12/14/2020)

HRSA understands that many 340B Program stakeholders are concerned about the evolving impact of COVID-19. If a covered entity has a specific concern about 340B eligibility or compliance, they should contact the 340B Prime Vendor via email  or at 1-888-340-2787 (Monday-Friday, 9:00 a.m. to 6:00 p.m. ET). For more information, visit the HRSA Office of Pharmacy Affairs COVID-19 Resources webpage.

(Added: 3/25/2020)

Please see the National Health Service Corps and Nurse Corps: Coronavirus (COVID-19) Frequently Asked Questions for information about these programs and their response to COVID-19.

(Updated: 3/30/2020)

HRSA is aware that many health centers are experiencing budget challenges associated with COVID-19. Health centers may draw grant funding from Payment Management System (PMS) for expenses in alignment with the health center's financial and operational policies and procedures and the approved grant budget. Acknowledging that this is an unprecedented time, health centers should consider the pace of their spending to ensure they have sufficient funds to avoid any funding shortfall.

As a reminder, advance payments to a Health Center Program awardee must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the awardee in carrying out the purpose of the approved program or project (per the Uniform Administrative Requirements at 45 CFR 75.305).

(Added: 3/19/2020)

The preferred method for accomplishing construction development is by soliciting through a competitive bid process consistent with 45 CFR §75.326 - §75.333. However, awardees may consider using their own work force (force account) if they can demonstrate that it would be cost effective and that qualified personnel are available to accomplish the work. You will need to provide the following information to HRSA for review:

• Justification for accomplishing the construction work by force account rather than by contract;
• Estimate of force account costs based on expected work hours, hourly rates, and non-salary costs;
• Estimate of contract construction costs based on typical items of work, quantities of work, and estimated unit prices;
• Summary cost comparison between using force account and contract construction;
• Names and qualifications of personnel to be used on the force account;
• Statement by the awardee concerning their capability to perform the various tasks of design, supervision, inspections, and testing as required for the intended project work;
• Statement by the awardee on the availability of their personnel to integrate the project into their normal workload; and
• Schedule identifying critical tasks and dates for when each task will be completed.

Additional information related to force account labor (PDF - 26 KB) is available from BPHC.

(Added: 5/21/2020)

In April 2020, HRSA determined that, due to the declared COVID-19 public health emergency and its impact on health center operations, the due dates for responses to Progressive Action conditions would be extended an additional 90 days. HRSA is now resuming the Progressive Action process. Accordingly, further extensions of Progressive Action condition due dates will NOT be provided.

Progressive Action conditions and compliance assessments are an important part of the Health Center Program monitoring and oversight process. HRSA is resuming Progressive Action condition progression and enforcement for those health centers with active conditions based on the extended due date reflected in EHBs. HRSA is providing advance public notice of resumed Progressive Action condition activity through this updated FAQ, and health centers with active conditions will also be notified through EHBs.

Health centers are encouraged to continue to submit documentation to demonstrate compliance by the condition submission due date. Project Officers remain available to provide guidance in line with the Health Center Program Compliance Manual and Progressive Action Conditions Library for any health centers with questions on active conditions.

(Updated: 6/24/2020)

Health Center Program requirements form the foundation and support the core mission of the health center model of primary care. However, HRSA recognizes that during this public health emergency there may be certain requirements with which a health center cannot demonstrate compliance within the timeframe or specific manner indicated in the Compliance Manual. (For example, staff may be unable to complete basic life support (BLS) re-certification in accordance with the health center’s timeline in its credentialing and privileging procedures, or there could be a delay in the release of the health center’s regular patient satisfaction survey.) HRSA will consider the impact of the COVID-19 public health emergency on the ability of health centers to demonstrate compliance with Health Center Program requirements when making future compliance determinations.

In addition to compliance, each health center is responsible for maintaining its operations, in compliance with all other applicable federal, state, and local laws and regulation beyond HRSA’s authority. This includes but is not limited to those protecting public welfare, the environment, and prohibiting discrimination; state facility and licensing laws; state scope of practice laws; Centers for Medicare & Medicaid Services (CMS) Conditions for Coverage for FQHCs; and state Medicaid requirements. For information on any flexibilities or waivers of other requirements, consult the applicable agency.

(Updated: 3/30/2020)

Yes, as indicated in the Health Center Program Compliance Manual, where geography or other circumstances make monthly, in-person participation in board meetings burdensome, health centers may conduct monthly meetings by telephone or other means of electronic communication where all parties can both listen and speak to all other parties.

(Added: 3/19/2020)

In accordance with current Health Center Program billing and collections requirements, health centers must make every reasonable effort to collect appropriate reimbursement for their costs, including billing Medicare, Medicaid, CHIP, and other public and private insurance or assistance programs, as applicable. Health centers must apply their sliding fee discount schedules consistent with their established policies and procedures.

Health centers’ application of their sliding fee discount programs through their billing systems also should take into account any reimbursement from all third-party payors (including any/all reimbursements under any insurance policy or health plan, or under any federal or state health benefits program), including any associated patient cost sharing requirements (i.e., copayments, deductibles, coinsurance, or restrictions on balance billing).

Consistent with health centers’ billing and collections procedures, health centers should ascertain whether there are available reimbursement, funding, or compensation sources and any related cost sharing restrictions for COVID-19 related testing or treatment prior to billing patients. If there are any patient out-of-pocket costs, health centers should apply their sliding fee discounts, which are based on income and family size. If there are any applicable prohibitions on patient cost sharing, after submitting their claims for reimbursement to the applicable payor source(s), health centers should not charge patients for such costs.

Each health center is responsible for ensuring adherence to any terms and conditions that apply to specific reimbursement, funding, or compensation sources for COVID-19 related testing and treatment. These include but are not limited to reimbursement from the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured Program and any funds received from the CARES Act Provider Relief Fund, which may include certain prohibitions regarding the balance billing of patients.

See the Health Center Program Compliance Manual for additional information on Health Center Program sliding fee discount requirements.

(Updated: 6/16/2020)

Health centers are required to continue providing sliding fee discounts and maximizing reimbursement, and they must continue to ensure that no patient is denied service based on inability to pay. However, consistent with Health Center Program requirements, health centers have discretion to amend policies (with board approval) and/or modify operating procedures in response to the COVID-19 public health emergency, as long as such changes are consistent with applicable statutory, regulatory, and policy requirements. This includes the flexibility to adjust policies and operating procedures for billing and collections and/or sliding fee discounts based on the unique circumstances of the health center and patient population served. These flexibilities may include but are not limited to:

• Offering additional billing options or payment methods (for example, payment plans, grace periods, mail-in options for payment) that address the need to limit in-person visits to the health center to reduce exposure for both patients and staff. The health center’s operating procedures for implementing these options or methods must ensure they are accessible to all patients regardless of income level or sliding fee discount pay class.
• Eliminating nominal charges for individuals and families at or below 100% of the Federal Poverty Guidelines.
• Revising the sliding fee discount schedule(s) to enhance effectiveness in reducing financial barriers to care. For example, health centers can adjust the percentages or reduce the amount of the fixed/flat fee used for discounting fees for patients with incomes between 100% and 200% of the Federal Poverty Guidelines.
• Adjusting procedures to assess patient eligibility for sliding fee discounts to accommodate the circumstances of the patient population. For example, the health center may permit self-declaration of income and family size due to the limitations of providing in-person documentation during the COVID-19 public health emergency.
• Expanding the specific circumstances the health center will consider when waiving or reducing fees or payments due to any patient’s inability to pay.

If health centers are discounting or waiving out of pocket costs, including co-pays for patients who have third-party coverage, such discounts may be subject to legal and contractual restrictions (i.e., any limitations that may be specified by applicable federal or state programs, or private payor contracts).

For more information, see Health Center Program Sliding Fee Discount Program requirements and Health Center Program Billing and Collections requirements.

(Added: 5/6/2020)

Health centers may not have a separate sliding fee discount schedule for telehealth. However, where the locally prevailing charges or the actual costs for services delivered via telehealth differ from those delivered in person, health centers may have different charges on a fee schedule. For example, if the cost of providing a primary health care visit through telehealth is less than an in person visit, the health center may establish a separate, lower charge for the telehealth primary care visit on the fee schedule. The health center would then apply their sliding fee discount schedule to the charge for the telehealth visit, which would be the same sliding fee discount schedule applied to an in-person primary care visit. For more information, see Health Center Program Billing and Collections requirements.

(Added: 5/6/2020)

In response to the COVID-19 public health emergency, HRSA has suspended in‐person site visits, including OSVs, through December 31, 2020. For the remainder of 2020, HRSA will conduct OSVs virtually. These virtual visits will take the place of health centers’ previously scheduled on-site OSVs. Most aspects of the virtual OSV will be the same as a traditional on-site OSV, but secure file sharing and video conferencing technology will allow for remote access to documents and participants. HRSA plans to use this virtual format until it is able to resume standard, on-site OSVs. Health centers due for a site visit will be contacted by HRSA to schedule and discuss the logistics of a virtual visit.

(Added: 9/10/2020)

At this time, health centers with active diabetes action plans from 2019 site visits are encouraged to resume and complete the performance improvement actions. HRSA will continue to offer flexibility regarding action plan quarterly report submissions. Health centers may submit quarterly reports; however, submission is optional. Project Officers will follow up with health centers on diabetes performance improvement actions as a part of routine program oversight.

(Updated: 7/28/2020)

HRSA continues to welcome LAL ID applications on a rolling basis. For additional information, see the LAL ID technical assistance webpage.

To be designated as a look-alike, applicants must meet eligibility requirements and comply with all Health Center Program requirements at the time of application. LAL ID site visits are a critical part of the look-alike designation process. In order to continue processing LAL ID applications during the current public health emergency, HRSA is conducting virtual site visits for LAL ID applicants who successfully meet completeness and eligibility requirements. HRSA will continue using the standard review process to finalize designation or disapproval, with timeframe accommodations based on the impacts of the COVID-19 public health emergency.

(Updated: 9/30/2020)

No. HRSA will shift from collecting IBHS tri-annual progress reports to monitoring health centers‘ progress at increasing new and/or existing patients receiving substance use disorder and/or mental health services through the submission of 2020 Uniform Data System (UDS) reports.

(Added: 4/7/2020)

For health centers that reported less than 0.5 FTE in their January 2020 progress report, HRSA has extended the due date of the 0.5 FTE requirement by 12 months to April 30, 2021. Health centers will be required to submit to HRSA a completed IBHS Staffing Impact Form that demonstrates a total of 0.5 FTE in substance use disorder and/or mental health personnel supported by fiscal year 2019 IBHS supplemental funding prior to April 30, 2021. For information, see your Notice of Award that provided year-two IBHS funding.

(Updated: 7/28/2020)

Lists of all public health emergency declarations and COVID-19 related declarations and waivers are available from the HHS Public Health Emergency website.

A public health emergency declaration lasts until the Secretary declares that the public health emergency no longer exists, or upon the expiration of the 90-day period beginning on the date the Secretary declared the public health emergency, whichever occurs first. The Secretary may extend the declaration for additional 90-day periods as long as the public health emergency continues to exist, or the Secretary may terminate the declaration whenever he determines that the public health emergency has ceased to exist.

(Added: 7/7/2020)

The CMS Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule outlines the expectations for health centers to develop and maintain an emergency preparedness communication plan and develop and maintain annual training and testing programs. Health centers must also coordinate with state and local health departments as part of their emergency management planning, preparedness, mitigation, and response efforts.

For information on how to coordinate with officials in your state regarding the state’s emergency preparedness or pandemic plan for the COVID-19 public health emergency, find your applicable point of contact.

(Added: 6/16/2020)

Health centers should refer to CDC Guidance for Healthcare Professionals about Coronavirus (COVID-19), which provides recommendations on caring for patients, protecting patients and workers, including infection control guidance for health care professionals, and facility guidance. In addition, health centers can contact their state, tribal, and/or local health departments for further guidance on patient safety and infection control and prevention. Lastly, health centers may wish to review the resources ECRI has developed through its COVID-19 Resource Center  and COVID-19 resources available through the Health Center Resource Clearinghouse.

(Updated: 7/28/2020)

If a health center's regular distributors are unable to fulfill orders for critical medical supplies such as PPE, the health center and/or the Primary Care Association should contact the local and/or state public health department for assistance. If the state is unable to provide supplies, state health officials — through the governor or his/her representative — may request federal assistance from the U.S. Department of Health and Human Services (HHS). Visit the HHS website for additional information and the current status of the SNS inventory.

(Updated: 4/29/2020)

As part of providing health services to their patients, health centers may have a role to play in COVID-19 contact tracing. Health center activities must be within the scope of section 330, should follow CDC and other applicable public health guidance, and should be coordinated as appropriate with federal, state, and local public health response efforts.

In providing care to patients with COVID-19, health centers should obtain information about the contacts of infected patients consistent with public health guidance, including guidance provided by the CDC. Health centers must report information on COVID-19 infections to federal, state, and local public health agencies consistent with applicable law (including laws relating to communicable disease reporting and privacy). In addition, in coordination with federal, state and local public health activities, health centers may notify identified contacts of infected health center patients of their exposure to COVID-19, consistent with applicable law (including laws relating to communicable disease reporting and privacy).

Health centers should be aware that activities other than those described above, as well as activities performed on behalf of a third party, including on behalf of a federal, state, or local public health agency, would constitute another line of business outside the scope of their Health Center Program project.

(Updated: 5/21/2020)

Health centers may participate in clinical research for COVID-19 vaccines and therapeutics within the Health Center Program scope of project incident to providing primary and approved additional health services to health center patients. Health centers that participate in such research must comply with all applicable laws and requirements, including but not limited to those pertaining to the protection of human research subjects (including requirements for informed consent and institutional review board approval) and ensuring privacy/confidentiality of patient health information. As the conduct of clinical research is highly regulated, health centers may wish to consult private legal counsel regarding applicable laws and requirements.

For more information regarding Health Center Program requirements related to patient safety and safeguarding the confidentiality of patient information, please review Chapter 10: Quality Improvement/Assurance (QI/QA) of the Health Center Program Compliance Manual. For information regarding health information privacy protection requirements, please review the HHS webpage on HIPAA for Professionals. For information on FTCA coverage for deemed health centers relating to clinical research, see Section C.5.5 Clinical research in the FTCA Health Center Policy Manual (PDF - 406 KB) and the question “Does FTCA coverage apply to health center staff engaged in COVID-19 clinical research trials?” in the FTCA section of this FAQ.

Health centers can also support COVID-19 research for vaccines and therapeutics by encouraging patient participation in clinical research studies conducted by other organizations. For example, the NIH National Institute of Allergy and Infectious Diseases is recruiting volunteers to participate in several clinical studies.

(Added: 10/23/2020)

Health centers are encouraged to review the CDC guidelines around reducing stigma. They describe actions health centers can take, such as maintaining the privacy and confidentiality of those seeking care, raising awareness of COVID-19 without increasing fear, and sharing accurate information about how the virus spreads.

(Added: 3/27/2020)

Health centers should follow all applicable public health guidance from state and local public health authorities regarding the modification or cessation of the delivery of specific services. The following guidance is available from the federal government:

• CDC information regarding the latest clinical or testing guidance for COVID-19
• Centers for Medicare & Medicaid Services (CMS) information regarding Medicare and Medicaid services during the COVID-19 public health emergency.
• CDC guidance for providers in dental settings during the COVID-19 response
• OSHA guidance for dentistry workers and employers
• OSHA guidance on joint recommendations issued by OSHA and HHS for all employers on preparing to reopen workplaces for COVID-19 (PDF - 1.1 MB) (also available in Spanish (PDF - 1.3 MB))

(Updated: 6/9/2020)

COVID-19 has led to a steep decline in routine immunizations, raising the risk for outbreaks and further strain on the nation’s health care system. Health centers play a critical role, as research shows the strongest predictor of whether a patient gets vaccinated is a recommendation from their health care professional.

To encourage patients and stakeholders to keep up with immunizations, the CDC has produced toolkits and resources to help health care professionals communicate with their patients about immunization. In addition, the CDC’s Interim Guidance for Immunization Services During the COVID-19 Pandemic can also help your health center plan for safe vaccine administration during the COVID-19 pandemic.

Health Center Program (H80), COVID-19 (H8C), and CARES (H8D) funds may be used to support the provision of routine immunizations—including influenza vaccines—provided such activities are within the health center’s scope of project. Health Center Program Expanded Capacity for Testing (ECT) (H8E) funds may not be used to support the provision of routine immunizations. More information about allowable uses of funding is available in the Other Uses of Funds section of the Health Center Program’s Coronavirus-Related Funding FAQs.

(Updated: 10/13/2020)

Health centers provide general primary care and other health services to their patients, consistent with applicable standards of care and practice. Health centers should familiarize themselves and comply with all such standards.

On November 9, 2020, the U.S. Food and Drug Administration issued an emergency use authorization for bamlanivimab, for the treatment of mild to moderate COVID-19 in adults and certain pediatric patients with positive COVID-19 test results and meeting other criteria who are at high risk for progressing to severe COVID-19 and/or hospitalization. Further information regarding bamlanivimab is available in the Fact Sheet for Health Care Providers – Emergency Use Authorization of Bamlanivimab (PDF - 239 KB).

Additional information regarding COVID-19 antibody treatment is also available:

• HHS Press Release
• CMS Press Release
• ASPR Portfolio of Monoclonal Antibody Treatments for COVID-19
• FDA Fact Sheet for Patients, Parents, and Caregivers – Emergency Use Authorization of Bamlanivimab (PDF - 166 KB)

(Added: 11/25/2020)

HHS Secretary Alex Azar issued a declaration of a national public health emergency regarding COVID-19 on January 31. As detailed in PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 185 KB): "HRSA recognizes that during an emergency, health centers are likely to participate in an organized state or local response, including by providing primary or preventive care services at temporary locations." Health centers may set up temporary sites that are “within the health center's service area or a county, parish, or other political subdivision adjacent to the health center's service area" (for in-scope services) with notification made to BPHC within 15 days. PAL 2020-05 (PDF – 185 KB) includes full details and requirements to ensure that the emergency response at temporary locations is considered part of the center's scope of project.

For purposes of FTCA coverage, patients served by covered individuals at temporary locations included in the covered entity's scope of project are considered the covered entity's patients. As such, the covered entity and its providers are covered by FTCA for services provided during the emergency at temporary locations." (See the FTCA Health Center Policy Manual (PDF – 408 KB) Section (I) F: A record of the services provided for each patient should be maintained.)

In addition, please see: Section (I) C.3 of the FTCA Health Center Policy Manual (PDF – 408 KB), Provision of Services to Health Center Patients, which states in part: "To meet the FTCA requirement of providing services to health center patients, a patient-provider relationship must be established. For the purposes of FSHCAA/FTCA coverage, the patient-provider relationship is established when: … Health center triage services are provided by telephone or in person, even when the patient is not yet registered with the covered entity but is intended to be registered."

Please also see the FTCA Health Center Policy Manual (PDF – 408 KB) Section (I) C.4 regarding Coverage in Certain Individual Emergencies.

Additionally, please see PAL 2017-07: Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations (PDF - 200 KB).

For questions about FTCA as it relates to emergency events, please contact Health Center Program Support online  or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

(Updated: 4/17/2020)

Site visits are a critical part of the oversight and compliance process for deemed health centers. In response to the COVID-19 public health emergency, HRSA has suspended in-person site visits temporarily, and will conduct virtual site visits as part of a pilot program beginning in November 2020. FTCA virtual site visits will be comparable to the onsite in-person process, but will include technological platforms such as secure file sharing and video conferencing to accommodate the virtual environment. Health centers selected for this pilot have been contacted by HRSA staff. For additional information and resources, please visit the FTCA webpage. For questions, please email the FTCA site visit team at BPHCFTCASiteVisit@hrsa.gov, or contact Health Center Program Support online  or by phone at 877-464-4772, option 1.

(Added: 10/21/2020)

When in-scope services are provided through telehealth on behalf of a deemed health center to either established patients or individuals who are not patients of the health center, and all other FTCA Program requirements are met, such services are eligible for liability protections under 42 U.S.C. 233(g)-(n), pursuant to 42 CFR 6.6 and the Determination of Coverage for COVID-19-Related Activities by Health Center Providers under 42 U.S.C. § 233(g)(1)(B) and (C) (the particularized determination for health center providers (PDF - 35 KB)).

The particularized determination clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of grant-supported health services by individuals who have been deemed as Public Health Service employees through the Health Center FTCA Program and the Health Center Volunteer Health Professional FTCA Program. It applies to grant-supported health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the health center, whether in person at the health center, offsite (including at offsite programs or events carried out by the health center), or via telehealth.

Health centers and providers are encouraged to consult with private counsel and/or consider the purchase of private malpractice insurance when undertaking activities that may not be within the health center’s scope of project.

(Updated: 6/2/2020)

Health Center FTCA Program regulations at 42 CFR Part 6 provide that coverage applies to “grant-related activities.” Therefore, a key determinant for FTCA coverage is whether the covered entity is providing services within the health center’s scope of project, under the Health Center Program authorizing statute.

PAL 2020-01: Telehealth and Health Center Scope of Project (PDF - 517 KB) highlights some of the relevant considerations for health centers in providing in-scope services through telehealth. Among other things, all providers must comply with applicable state requirements. If they do not—for example, if a provider uses a state license to provide services in a different state where doing so is unlawful under applicable state law—this may jeopardize eligibility for FTCA liability protection. However, some states may have temporarily amended their requirements for providing health care through telehealth to address the needs of the COVID-19 public health emergency.

Health centers that are uncertain of the applicable legal requirements for the provision of health services through telehealth across state lines should consult their private counsel for advice. HRSA cannot provide general assurance of FTCA coverage in all situations, as such determinations are fact-specific. As stated in the FTCA Health Center Policy Manual (PDF - 407 KB), “[w]hen FTCA matters become the subject of litigation, the Department of Justice and the federal courts assume significant roles in certifying or determining whether or not a given activity falls within the scope of employment for purposes of FTCA coverage.”

(Added: 4/8/2020)

See PAL 2017-07: Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations for guidance (PDF – 288 KB).

(Added: 3/19/2020)

Yes, the 21st Century Cures Act (Pub. L. 114-255) extended liability protections to Volunteer Health Professionals (VHPs) for the performance of medical, surgical, dental, and related functions at health centers. For liability protections to apply under section 224(q) of the Public Health Service Act (42 U.S.C. § 233(q)), the volunteer must be a health care professional who is licensed or certified to provide clinical services. This would include Licensed Practical Nurses (LPNs) and Medical Assistants (MAs) who are licensed or certified. Volunteers who are not licensed or certified are not eligible for VHP coverage.

VHPs are not automatically eligible for liability protections under the Health Center FTCA Program. Deemed health centers must apply for such protections for their individual volunteers through a VHP deeming sponsorship application. See Program Assistance Letter (PAL) 2020-03: Calendar Year 2021 Volunteer Health Professional Federal Tort Claims Act (FTCA) Deeming Sponsorship Application Instructions (PDF – 184 KB). The deemed health center must submit to HRSA and receive approval of a VHP deeming sponsorship application for each individual volunteer.

(Updated: 4/7/2020)

Health centers can complete a VHP deeming sponsorship application by accessing the Electronic Handbooks (EHBs) and going to the FTCA application section. The EHBs allow sponsoring health centers to submit multiple VHPs in one application submission. For assistance with this process, please contact Health Center Program Support online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

Applications for VHP deeming must be submitted by the health center's Authorized Official. However, health centers may seek technical assistance in preparing and submitting such applications from PCAs and other third parties.

(Added: 3/19/2020)

Health centers and their providers are strongly encouraged to exercise caution, as FTCA liability protections may be placed at risk when a provider acts on behalf of more than one entity under circumstances that do not make it clear in what capacity the individual was acting at the time of an event that becomes the subject of a claim or lawsuit. Health centers are reminded that when FTCA matters become the subject of litigation, the U.S. Department of Justice and the federal courts assume significant roles in certifying or determining whether a given activity falls within the scope of employment for purposes of FTCA coverage. Health centers and providers are encouraged to consult with private counsel and/or consider the purchase of private malpractice insurance when individual providers wish to undertake activities on behalf of multiple entities and/or in multiple capacities.

(Added: 3/19/2020)

Continuous or permanent staffing of a hospital or hospital department to provide inpatient care to all hospital patients is not described by the authorizing statute for the Health Center Program, and FTCA coverage generally is not available for such care.

Health centers have discretion to enter into contractual arrangements with hospitals or may allow their providers to enter into arrangements with hospitals to provide hospital-based inpatient care outside the scope of their Health Center Program grants. However, FTCA coverage and other federal benefits directly associated with the Health Center Program would not apply. Providers providing continuous or permanent inpatient care in hospitals through such arrangements may have medical malpractice liability protection through the hospital or another source, and volunteer providers may be eligible for liability protections under federal and state law (including new legal protections for volunteer providers for COVID-19 emergency response via the CARES Act). Health centers should consult with private counsel for legal advice regarding these matters.

Please note that the Health Center FTCA Program regulations and the March 27, 2020, Determination of Coverage for COVID-19-Related Activities by Health Center Providers (PDF - 35 KB) provide for FTCA protection for deemed health centers in the circumstances described in those issuances. The March 27, 2020, Determination of Coverage indicates that health center providers may provide grant-supported health services “to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment)” to individuals who are not patients of the health center, whether at the health center or off-site, and whether in-person or through telehealth. This determination of coverage extends to local COVID-19 community-wide emergency response activities supported by the health center. The Health Center FTCA Program regulations also provide for liability protections for certain described individual emergency situations.

The Health Center Program provides grant support for the delivery of primary and preventive health care service to medically underserved populations and communities. Services provided through the Health Center Program generally consist of outpatient, ambulatory care services for health center patients. As provided for by statute, regulation, and determination of coverage, services may be provided to individuals who are not patients of the health center in limited circumstances.

(Added: 4/16/2020)

Yes. In responding to the declared public health emergency, otherwise qualified free clinic health care practitioners, employees, and contractors who have been deemed as Public Health Service employees for purposes of liability protections through the Free Clinics FTCA Program are eligible for such protections for screenings and triage activities relating to the diagnosis and treatment of COVID-19, as well as for other qualifying health services, provided to patients and other individuals seeking such services from the free clinic. These services may be provided at the free clinic or offsite, including at offsite programs or events carried out by the free clinic, which includes providing services on behalf of the free clinic at “drive-up” screening locations in the free clinic parking lot or in other nearby locations.

Free clinic providers located at the free clinic or in such other locations may also utilize telehealth to facilitate the delivery of services to free clinic patients and other individuals. All such contact must be appropriately documented in free clinic patient medical records. In addition, all other Free Clinics FTCA Program requirements remain applicable. For additional information, see Policy Information Notice 2011-02: Free Clinics Federal Tort Claims Act (FTCA) Program Policy Guide (PDF - 381 KB), and the Free Clinics FTCA Program website.

(Added: 3/27/2020)

Yes. The definition of a “free clinic,” as established by the authorizing statute for the Free Clinics FTCA Program, requires that the entity not seek reimbursement for the health care that it provides. Section 233(o)(3) of title 42, United States Code, states in pertinent part: “the entity does not, in providing health services through the facility, accept reimbursement from any third-party payor (including reimbursement under any insurance policy or health plan, or under any Federal or State health benefits program).” In addition, 42 U.S.C. § 233(o)(2)(D) precludes a health care practitioner or free clinic from receiving “any compensation for [a health service] from the individual or from any third-party payor (including reimbursement under any insurance policy or health plan, or under any Federal or State health benefits program).”

HRSA’s Provider Relief Fund frequently asked questions state the following:

The COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured Program provides reimbursements on a rolling basis directly to eligible providers for claims that are attributed to the testing and treatment of COVID-19 for uninsured individuals.

Health care providers who have conducted COVID-19 testing of uninsured individuals or provided treatment to uninsured individuals with a COVID-19 diagnosis for dates of service or admittance on or after February 4, 2020 may be eligible for claims reimbursement through the program as long as the service(s) provided meet the coverage  and billing  requirements established as part of the program.

Under the Free Clinics FTCA Program, an entity that accepts or receives reimbursement for the provision of health services from a third-party payor is not eligible to sponsor a provider deeming application, nor may the entity or the provider accept such compensation for the service provided. Accepting such reimbursement may therefore place at risk the availability of liability protections under this statute for the actions of the entity’s deemed providers. Free clinics should consult private counsel as needed for legal advice.

For additional information, see PIN 2011-02: Free Clinics Federal Tort Claims Act (FTCA) Program Policy Guide (PDF - 380 KB).

(Added: 5/20/2020)

HRSA has issued a particularized determination for health center providers (PDF - 35 KB) that clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of grant-supported health services by individuals who have been deemed as Public Health Service employees through the Health Center FTCA Program and the Health Center VHP FTCA Program. It applies to grant-supported health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the health center, whether in person at the health center, offsite (including at offsite programs or events carried out by the health center), or via telehealth.

(Added: 3/31/2020)

HRSA has issued a particularized determination for free clinic providers (PDF - 34 KB) that clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of qualifying health services by individuals who have been deemed as Public Health Service employees through the Free Clinics FTCA Program. It applies to qualifying health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the free clinic, whether in person at the free clinic, through responsive offsite programs or events carried out by the free clinic, or via telehealth.

(Added: 3/31/2020)

A deemed health center would be eligible for FTCA coverage for COVID-19 screening, triage, testing and diagnosis activities, including notifying identified contacts of infected health center patients of their exposure to COVID-19, consistent with applicable law (including laws relating to communicable disease reporting and privacy), as part of their scope of project and as reflected on Form 5A: Services Provided. These services are considered part of Required Services such as General Primary Medical Care, Screenings, and Diagnostic Laboratory.

Health centers participating in community-wide intervention efforts—which may include partnering with state and local health departments for contact tracing—would be operating within their scope of project, so long as the related services are conducted on behalf of the health center.

HRSA has issued a particularized determination (PDF - 35 KB) for health center providers that clarifies eligibility for FTCA coverage during the COVID-19 pandemic for the provision of grant-supported health services by individuals who have been deemed as Public Health Service employees through the Health Center FTCA Program and the Health Center VHP FTCA Program. The particularized determination applies to grant-supported health services to prevent, prepare, or respond to COVID-19 (including but not limited to screening, triage, testing, diagnosis, and treatment) to individuals who are established or non-established patients of the health center, whether in person at the health center, offsite (including at offsite programs or events carried out by the health center), or via telehealth."

For more information regarding eligibility and applicability of FTCA coverage, see the FTCA Health Center Policy Manual (PDF - 35 KB), Section B. Covered Individuals, and Section C. Covered Activities.

(Added: 5/6/2020)

Under FTCA Health Center Program regulations at 42 CFR 6.6(d), only acts and omissions related to the grant-supported activities of entities covered by FTCA are eligible for FTCA coverage. Acts and omissions related to services provided to individuals who are not patients of a deemed health center (“covered entity”) are eligible for coverage only in limited circumstances and after the Secretary makes certain required determinations.

Therefore, as explained in Section C.5.5 of the FTCA Health Center Policy Manual (PDF - 406 KB), clinical research in the context of patient care, conducted by covered individuals with covered entity patients, qualifies for FTCA coverage if it is within the approved scope of project of the covered entity and the scope of employment of the covered individuals with the covered entity. To the extent that research involves non-health center patients, it is not covered by FTCA.

(Added: 9/17/2020)

Through the Health Center FTCA Program regulations, HRSA has issued several examples of situations in which deemed health centers and their covered providers have liability protections for certain activities carried out by the deemed entity and its eligible personnel. Under 42 CFR 6.6(e)(4)(D):

(D) Immunization Campaigns: On behalf of the health center, health center staff conduct or participate in an event to immunize individuals against infectious illnesses. The event may be held at the health center, schools, or elsewhere in the community.

For additional information about FTCA Program requirements, please refer to the FTCA section of the Health Center Program website, which includes links to the FTCA Health Center Policy Manual (PDF - 406 KB), Annual Deeming Application PAL (PDF - 452 KB), and Annual VHP Deeming Application PAL (PDF - 183 KB), along with other resources that provide information and instructions regarding eligibility for liability protections for health center employees, board members, officers, contractors, and volunteers.

(Added: 8/20/2020)

For additional information in determining whether activities are performed on behalf of the health center, please review Considerations for Health Center Scope of Project and the COVID-19 Public Health Emergency. HRSA has a streamlined process outlined in PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 185 KB).

HRSA approval is required any time a health center will add a temporary site(s) in response to emergency events when the location would meet the service site definition as defined in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF – 28 MB). The information needed for this request must be submitted as soon as practicable but no later than 15 days after initiating emergency response activities. See also the FTCA Health Center Policy Manual (PDF - 406 KB), particularly Section (I)(C), and the Determination of Coverage for COVID-19-Related Activities by Health Center Providers.

(Added: 8/20/2020)

Health centers do not need to request HRSA prior approval via a change in scope in cases where they are temporarily closing a site due to the public health emergency. Health centers should ensure their patients are made aware of closures and where and how to seek care at other service delivery sites as appropriate.

If a health center determines that it will permanently close a site after the public health emergency, it must submit a change in scope for HRSA approval to delete the site.

(Added: 3/19/2020)

HRSA recognizes that during the declared emergency health centers may face staffing shortages and/or facility capacity limitations and may need to prioritize appointments and staffing to address the most urgent needs of patients. No change in scope is necessary if your health center is changing the level or intensity of certain services within the scope of project. If a health center permanently removes a service from its scope of project, a change in scope request to delete the service will need to be submitted for HRSA approval.

(Added: 3/17/2020)

Yes. COVID-19 screening, triage, or testing of health center patients performed on behalf of the health center are elements of general primary care and diagnostic laboratory services as reflected on Form 5A: Services Provided.

The Health Center Program views providing screenings, triage, and testing to any patient — including both established health center patients and individuals who are not established patients of the health center – at the health center, outside on its grounds, or elsewhere in the community as within the health center's scope of project (see 42 CFR 6.6 (e)(4)(i)(C)). This includes providing such screening, triage, or testing to patients in the parking lot of the health center or in other community locations.

(Updated: 6/18/2020)

Sites recorded on Form 5B: Service Sites must be locations that meet the definition of a service site in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB). Specifically, these are locations where all of the following conditions are met:

• Health center encounters are generated by documenting in the patients’ records 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). However, there is no minimum number of hours per week that services must be available at an individual site.

Health centers may be engaged in a variety of different COVID-19 testing activities (screening, triage, specimen collection, etc.). To determine whether COVID-19 testing should be categorized on Form 5B: Service Sites or Form 5C: Other Activities/Locations, a health center must determine if the location meets all site criteria above. If all site criteria are not met — particularly if testing is provided on an irregular timeframe/schedule (e.g., the health center provides testing for short periods of time at a variety of locations) — this would generally be considered portable clinical care and documented on Form 5C: Other Activities/Locations.

View additional information on considerations for health center scope of project during the COVID-19 public health emergency.

(Added: 7/8/2020)

HRSA recognizes that health centers may need to change the hours of operation of their service sites during the declared emergency. No change in scope is necessary if your health center is temporarily increasing or decreasing hours of operation at one or more sites. If a health center permanently changes the hours of operation at one or more sites, they should submit a scope adjustment (PDF - 432 KB) request for HRSA approval. As with any changes that may have impacts on access to care, health centers should ensure patients are made aware of changes to site hours of operation.

(Added: 4/7/2020)

As a result of the Secretary's declaration relating to the current COVID-19 public health emergency, health center providers may deliver in-scope services via telehealth to individuals who have not previously presented for care at a health center site and who are not current patients of the health center for the duration of this public health emergency. This includes triage services, including initial consultations. Telehealth visits are within the scope of project if:

• The individual receives an in-scope required or additional health service;
• The provider documents the service in a patient medical record consistent with applicable standards of practice; and
• The provider is physically located at a health center service site or at some other location on behalf of the health center (e.g., provider’s home, emergency operations center).

Health centers should focus services provided by telehealth on serving patients and other individuals located inside their service area or with areas adjacent to the covered entity’s service area. HRSA recognizes that patients outside these areas may seek health center screenings and triage by telehealth. Health centers that continue to maintain services for target populations in their service area and provide occasional in-scope services via telehealth to individuals outside these areas would be providing services within the Health Center Program scope of project for all such activities. Please review PAL 2020-01: Telehealth and Health Center Scope of Project (PDF – 520 KB) for more information.

(Added: 3/19/2020)

From a Health Center Program scope of project policy perspective, using telehealth to provide services to a patient at a location that is not an in-scope service site is allowable if:

1. The service being provided via telehealth is within the health center's approved scope of project (recorded on Form 5A);
2. The clinician delivering the service is a health center provider working on behalf of the health center; and
3. The individual receiving the service is a health center patient.

HRSA strongly encourages health centers that provide, or are planning to provide, health services via telehealth to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Health Center Program requirements; federal, state, and local requirements; and applicable standards of practice. HRSA also encourages health centers to consider the range of issues that would support successful implementation of telehealth. Please review PAL 2020-01: Telehealth and Health Center Scope of Project (PDF – 520 KB) for more information.

For questions about FTCA coverage, please contact Health Center Program Support  online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

(Updated: 4/7/2020)

Health centers do not need to request a change in scope to deliver in-scope services via telehealth on behalf of the health center from the provider’s home or from another location that is not a Form 5B Service Site. In addition, health centers do not need to have "Home Visits" listed on their Form 5C: Other Activities/ Locations in order to provide in-scope services via telehealth.

For questions about FTCA coverage, please contact Health Center Program Support  online or call for FTCA assistance at 877-464-4772, 8:00 a.m. to 5:30 p.m. ET, Monday-Friday (except federal holidays).

(Added: 4/7/2020)

The HHS Office for Civil Rights issued a Notification of Enforcement Discretion for telehealth remote communications during the COVID-19 nationwide public health emergency on March 17, 2020, which indicates HHS will not impose penalties for noncompliance with regulatory requirements under HIPAA rules in connection with the good faith provision of telehealth during the COVID-19 emergency. There are also Frequently Asked Questions on telehealth (PDF - 94 KB) available.

Providers, including health centers, now have greater flexibility to provide telehealth using any non-public facing remote communication product that is available to communicate with patients (Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype). Note that according to this notification, Facebook Live, Twitch, and TikTok are not allowable applications. See the notification for additional details.

(Added: 3/25/2020)

During this emergency period, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are eligible to provide telehealth services to Medicare beneficiaries as distant site providers.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act revises the definition of a distant site in section 1834(m)(2)(A) of the Social Security Act to include FQHCs or RHCs that furnish a telehealth service to an eligible telehealth individual during the COVID-19 public health emergency period. Rural and site limitations are removed, so that telehealth services furnished during the emergency period can be provided regardless of the geographic location of the Medicare beneficiary, including if the patient is at home. Telehealth services include medical outpatient office visits, behavioral health services, and other visits currently eligible under the Medicare telehealth reimbursement policies.

Medicare telehealth services generally require an interactive audio and video telecommunications system that permits real-time communication between the practitioner and the patient. However, during the public health emergency, some telehealth services can be furnished using audio-only technology. For more information, please visit the following CMS resources:

• COVID-19 FAQs on Medicare Fee-for-Service (FFS) Billing (PDF - 662 KB);
• CMS Flexibilities to Fight COVID-19 (PDF - 317 KB); and
• CMS and Medicare Learning Network’s New and Expanded Flexibilities for RHCs and FQHCs During the COVID-19 Public Health Emergency (PDF - 253 KB).

(Updated: 6/3/2020)

Medicare has provided new guidance on the payment method for telehealth services furnished by FQHCs as distant sites during the emergency period. The CARES Act requires the Centers for Medicare & Medicaid Services (CMS) to develop payment rates similar to the national average payment rates for comparable telehealth services under the Physician Fee Schedule (PFS). CMS has set that rate at $92.03, which is the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS. For telehealth services furnished between January 27, 2020, and June 30, 2020, FQHCs will be reimbursed for telehealth services based on their Prospective Payment System (PPS) rate. These claims will be automatically reprocessed in July when the claims system is updated with the new telehealth payment rate. After July 1, 2020, through the end of the COVID-19 public health emergency, FQHCs will use a specific G code (G2025) and will be paid at the $92.03 rate. CMS has additional information on the submission of claims and reimbursement.

(Updated: 5/14/2020)

States have the discretion to cover telehealth through Medicaid; no federal approval is needed for state Medicaid programs to reimburse for telehealth services in the same manner or at the same rate paid for face-to-face services, visits, or consultations. The Center for Connected Health Policy (a National Telehealth Resource Center) has published a summary of state telehealth responses to COVID-19 , including Medicaid coverage. For additional Medicaid information, please visit the Medicaid telemedicine webpage and the COVID-19 resources for state Medicaid and CHIP agencies.

(Updated: 10/21/2020)

CMS has information (PDF - 476 KB) on flexibilities for telehealth reimbursements provided for state Medicaid and Children’s Health Insurance Program (CHIP) agencies. In particular, see the question on telehealth reimbursement flexibilities to cover teledentistry (page 36).

For additional training and technical assistance resources, visit the National Network for Oral Health Access (NNOHA), a HRSA-funded National Training and Technical Assistance Partner, for teledentistry resources . See also resources  summarizing state telehealth responses to COVID-19, including Medicaid coverage, developed by the Center for Connected Health Policy (a National Telehealth Resource Center).

(Added: 6/9/2020)

States regulate the practice of medicine and other health professions as part of their authority to establish laws and regulations to protect the health, safety, and general welfare of their citizens. If your state authorizes health practitioners to provide services outside their usual areas of licensure/certification/practice, this should be documented in the health center’s credentialing files, along with fulfillment of any additional requirements for credentialing and privileging.

(Added: 4/7/2020)

In response to emergency events, health centers can temporarily add sites (including tents, modular units, or trailers) that are not currently within the scope of project. These requests are not submitted through the EHBs; a health center simply provides key information to its Project Officer by email or phone. Health centers may wish to review the Considerations for Health Center Scope of Project and the COVID-19 Public Health Emergency, prior to requesting the addition of a temporary site.

Temporary sites must be locations that meet the definition of a service site in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB) as a location where all of the following conditions are met:

• Health center encounters are generated by documenting in the patients’ records 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). However, there is no minimum number of hours per week that services must be available at an individual site.

HRSA’s streamlined process for adding temporary sites during emergencies is described in PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 185 KB). Your Project Officer may contact you for additional information about your activities at the new locations so that HRSA can better determine if your request meets the criteria.

(Updated: 8/20/2020)

HRSA approval is not required for the provision of in-scope health center services at the following locations if these locations are already within your approved scope of project, i.e., documented on Form 5B or Form 5C, including but not limited to:

• A health center service site (on Form 5B), including any new modular units, tents, or trailers on the grounds of the 5B site;
• Mobile units (on Form 5B), including delivering in-scope services via mobile units at additional locations in the health center’s service area;
• Home visits (on Form 5C) to health center patients, including visiting health center patients in assisted living facilities and nursing homes; or
• Portable clinical care or health fairs (on Form 5C), where health center staff conduct clinical care or COVID-19 testing outside of health center sites (for example, conducting screenings, testing, or consultations in a parking lot or on the street to individuals experiencing homelessness). These activities may be coordinated with state or local health department or other community providers as long as these services are provided on behalf of the health center.

(Added: 3/30/2020)

As a result of the Secretary's declaration relating to the current COVID-19 public health emergency, HRSA considers all health centers impacted and “eligible” to submit change in scope requests to add temporary sites due to an emergency, if necessary.

(Updated: 3/24/2020)

HRSA approval is required anytime a health center will add a temporary site(s) in response to emergency events when the location would meet the service site definition as defined in Policy Information Notice (PIN) 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF – 28 MB). The information needed for this request must be submitted as soon as practicable but no later than 15 days after initiating emergency response activities. HRSA has a streamlined process outlined in PAL 2020-05: Requesting a Change in Scope to Add Temporary Service Sites in Response to Emergency Events (PDF - 185 KB).

(Updated: 4/17/2020)

HRSA’s approval of the temporary service site will automatically expire 90 days after the temporary service site’s approved effective date. To request an extension to operate a temporary site beyond 90 days, contact your Project Officer by email or phone.

(Added: 5/6/2020)

CMS has waived certain regulatory requirements for the duration of the COVID-19 public health emergency, providing flexibilities to assist Federally Qualified Health Centers, including Health Center Program awardees and look-alikes, in furnishing services at temporary locations. Updated information on these flexibilities is available from CMS (PDF - 172 KB).

During the public health emergency, additional flexibilities introduced by CMS include those related to:

• The physician supervision requirement for nurse practitioners (PDF - 1 MB), to the extent permitted by state law;
• Telehealth services (PDF - 253 KB); and
• Medicare billing (PDF - 662 KB).

For information on how to coordinate with officials in your state regarding the state’s emergency preparedness or pandemic plan for the COVID-19 public health emergency, find your applicable point of contact.

(Added: 6/16/2020)

Health centers should provide COVID-19 testing services to established patients and other individuals who present for such services and meet criteria for COVID-19 testing, regardless of ability to pay. Criteria for testing should be informed by CDC guidelines on testing for SARS-CoV-19, as well as by state, tribal, or local public health guidance.

If a health center does not have sufficient capacity to test beyond its established patient population (e.g., limited Personal Protective Equipment (PPE), testing supplies, or staff capacity), then the center should make efforts to refer patients to other appropriate providers.

For PPE and testing supply needs, health centers should communicate and coordinate with state, tribal, and local health departments and Primary Care Associations in their state, in addition to reporting these needs in the weekly HRSA Health Center COVID-19 Survey.

(Added: 7/7/2020)

Health centers may purchase and use both diagnostic and antibody tests as part of their scope of project. The term "diagnostic test" generally refers to a molecular or antigen test, both of which can be used to diagnose infection with the SARS-CoV-2 virus. The terms "antibody test" or "serological test" generally refer to tests that detect antibodies to the SARS-CoV-2 virus. More information is available in the Food and Drug Administration’s FAQs on Testing for SARS-CoV-2. Health centers should consult with their state and local health departments for additional guidance on procuring and utilizing COVID-19 tests.

The following sites have resources and guidance on testing and specimen collection:

• FDA Guidance on Diagnostic Testing for SARS-CoV-2
• CDC Guidance on Evaluating and Testing Persons for COVID-19
• CDC Interim Guidelines for Collecting, Handling, and Testing Clinical Specimens from Persons for COVID-19

For specific questions regarding eligibility and applicability of Federal Tort Claims Act coverage, see the FTCA Health Center Policy Manual (PDF - 407 KB), Section C. Covered Activities, and the March 27, 2020, Determination of Coverage for COVID-19-Related Activities by Health Center Providers  (PDF - 35 KB).

(Updated: 5/19/2020)

States regulate the practice of medicine and other health professions as part of their authority to establish laws and regulations to protect the health, safety, and general welfare of their citizens. Each health center is therefore responsible for maintaining its operations, including developing and implementing its own operating procedures, in compliance with all Health Center Program requirements and all other applicable federal, state, and local laws and regulations (42 CFR 51c.304(d)(3)(v)). This includes requirements regarding laboratory and personnel related to COVID-19 testing.

• Health centers that provide COVID-19 testing must comply with their state’s clinical laboratory laws, including any personnel and training requirements for specimen collection and/or the performance of clinical laboratory testing.
• Health centers must also comply with any applicable CLIA requirements, based on the complexity of the testing. See CLIA Laboratory Guidance During COVID-19 Public Health Emergency (PDF - 220 KB) and additional updates from CMS.
• Health centers must ensure that any clinical staff conducting specimen collection and testing are appropriately trained, qualified, and, if necessary, supervised, consistent with the health center’s credentialing and privileging procedures. This includes health centers that operate in states, territories, or jurisdictions that do not require licensure or certification for certain clinical staff (e.g., medical assistants) that may be involved in specimen collection.
• If your state authorizes health practitioners (dentists, medical assistants, etc.) to provide services, including COVID-19 specimen collection, outside their usual areas of licensure/certification/practice, this should be documented in the health center’s credentialing files, along with fulfillment of any additional requirements for credentialing and privileging.

For specific questions regarding eligibility and applicability of FTCA coverage, see the FTCA Health Center Policy Manual (PDF - 407 KB), Section C. Covered Activities, and the March 27, 2020, Determination of Coverage for COVID-19-Related Activities by Health Center Providers (PDF - 35 KB).

(Added: 5/6/2020)

The Centers for Medicare & Medicaid Services (CMS) issued a memorandum to laboratory surveyors (PDF - 219 KB) providing guidance regarding the review of pathology slides, proficiency testing, alternate collection devices, and requirements for a CLIA certificate during the COVID-19 public health emergency.

Of note for health centers, CMS will be expediting review of applications for a CLIA certificate and will allow for testing to begin once a CLIA number has been assigned, as opposed to laboratories waiting for a hard copy paper certificate to come in the mail. CMS is also exercising enforcement discretion and will not enforce the requirement to have a separate certificate for laboratories that are located at a temporary testing site, provided that the designated primary site has such a certificate (using the address of the primary site) and the work being performed in the temporary testing site falls within the parameters of the primary site's certificate. A temporary testing site is where, at various intervals, an entity that is not at a fixed or permanent location performs laboratory testing.

In addition, CMS will permit a laboratory to extend its existing CLIA certificate to operate a COVID-19 temporary testing site in an off-site “designated overflow location” such as a school, church, or parking lot (with approval of local and state authorities). The temporary site is only permitted to perform tests, consistent with the existing certificate, and must be under the direction of the primary site/home base existing lab director.

(Added: 5/4/2020)

Health centers performing testing need to know whether a test system is waived, moderate, or high complexity for each test on their menu because this determines the applicable CLIA requirements. The complexity categorization or waiver status for a test may be printed in the manufacturer’s package insert or other instructions. The following FDA and CMS sites can help you determine the level of complexities for certain tests:

• FDA’s Searchable CLIA Database
• FDA’s Currently Waived Analytes
• FDA’s Emergency Use Authorization
• CMS' CLIA Testing Requirements for SARS-CoV-2 (includes infographic) (PDF - 496 KB)

(Added: 5/6/2020)

Health centers should coordinate with state and local health departments and Primary Care Associations in their state to support their ability to identify alternatives for lab processing capacity.

(Added: 5/6/2020)

For testing supply and equipment needs, health centers should communicate and coordinate with state, tribal, and/or local health departments and their state or regional Primary Care Associations. If those channels are unable to provide support, health centers can reach out to HHS Resource Coordination to request assistance.

In addition, health centers should continue to report these needs in the weekly Health Center COVID-19 Survey. While HRSA does not have access to testing supplies for health centers, the data provided in these surveys provides critical information regarding the impact of COVID-19 on health center operations, patients, and staff, which HRSA shares with other agencies and partners. The data is also used to better understand trends that influence health center training and technical assistance, funding, and other resource needs.

(Updated: 9/30/2020)

Yes. Health Center Program funding may be used to support a wide-range of COVID-19 testing and testing-related in-scope activities, and this includes using these funds to support COVID-19 prevention and response by making available COVID-19 self-swab specimen collection kits to health center patients, consistent with FDA’s clearance, approval, or authorization of such kits.

Prescribing and providing access to at-home COVID-19 self-swab specimen collection kits to established health center patients is an available component of a health center’s general primary care for its patients when used consistent with FDA clearance, approval, or authorization. HRSA recommends that health centers follow CDC guidelines on COVID-19 testing and ensure compliance with all applicable FDA guidance for such testing.

Health centers that choose to make available to patients COVID-19 at-home self-swab specimen collection kits should:

• Ensure that they do so in compliance with the currently applicable FDA Emergency Use Authorization (EUA) for the specific test used.
• Follow the specific uses authorized within the applicable EUA, including any noted need for provider supervision of the specimen collection and any applicable limitations on use of the test. The FDA FAQ on Testing for SARS-CoV-2 provides more information on COVID-19 tests that are authorized for use with home specimen collection kits.
• Ensure appropriate follow-up, including on positive COVID-19 test results. Such follow-up may include, but is not limited to:
  • Guidance on self-monitoring for worsening symptoms.
  • Steps for isolation to reduce risk of transmission.
  • Making medically indicated referrals of patients.
  • Providing connections to community-based support resources.

(Added: 8/20/2020)

Health centers considering testing of persons with possible COVID-19 should coordinate with state and local health departments on reporting requirements for both positive and negative cases. The following CDC sites have resources on testing, reporting, and specimen collection:

• COVID-19 Testing and Reporting by Laboratories: Q & A
• Interim Guidelines for Collecting, Handling, and Testing Clinical Specimens from Persons for COVID-19

(Added: 5/6/2020)

A sentinel surveillance system utilizes a limited network of reporting sites to rapidly signal trends, identify outbreaks, and monitor the burden of disease such as COVID-19. Health centers may provide COVID-19 testing data to sentinel surveillance systems consistent with applicable law.

For more information on surveillance activities that support the COVID-19 response, please see CDC Activities and Initiatives Supporting the COVID-19 Response and the President’s Plan for Opening America Up Again (PDF - 1.4 MB).

(Added: 6/16/2020)

HRSA’s Find a Health Center tool allows users to find health centers that are currently offering COVID-19 testing and/or are providing services via telehealth at one or more of their sites. To find out which specific sites are offering testing or telehealth, prospective patients are urged to contact the health center directly. Phone numbers are available via the Find a Health Center tool. Data about testing and telehealth availability are updated regularly based on the weekly Health Center COVID-19 Survey.

(Added: 8/3/2020)

Yes, for 2020 UDS reporting, COVID-19 temporary sites that meet HRSA’s site criteria (as listed on Form 5B (PDF - 575 KB)) are included in the health center’s scope of project. Services that occur at these sites are counted in UDS reporting. For additional information on temporary sites, refer to the Temporary Sites category above. For additional information on how to count COVID-19 tests in the UDS report, see the question below.

(Updated: 5/21/2020)

Yes, as long as they are allowable UDS case management visits or patient and community education visits as defined in the 2020 UDS Manual (PDF - 1.9 MB) (Instructions for Table 5: Staffing and Utilization section) and meet the UDS definition of virtual visits.

(Added: 5/14/2020)

Staff reporting is based on full-time equivalents (FTE), in alignment with the guidance provided in the UDS Manual (PDF - 1.9 MB). If an employee was being paid while on leave, they are to be counted in the FTEs reported in Table 5. If an employee was on unpaid leave, furloughed, or laid off during the reporting year, any portion of the year where they were not being paid by the health center or not employed by the health center should not be included in Table 5. Staff providing services outside the scope of the health center project are also not to be included. For additional information, see the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

Volunteer health care providers and their services at health centers during the pandemic should be reported as specified in Appendix B in the UDS Manual (PDF - 1.9 MB).

(Added: 5/14/2020)

The number of patients served and visits associated with COVID-19 and associated respiratory illnesses diagnoses will be collected in the 2020 UDS on Table 6A. This table will also collect the number of patients served and visits associated with COVID-19 testing. Additional details are included in the 2020 UDS Manual (PDF - 1.9 MB) and the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

Yes, if a telehealth visit meets the CQM’s denominator and/or numerator specifications as directed by the measure steward, as well as the UDS’ virtual visit definition, it may be counted.

The UDS defines virtual visits as those that use interactive, synchronous audio and/or video telecommunication systems permitting real-time communication between the provider and a patient. For a list of the CQM measure stewards, refer to Appendix G: UDS CQMs and National Programs Crosswalk, in the UDS Manual (PDF - 1.9 MB). Measurement specifications are available from the Electronic Clinical Quality Improvement Resource Center. For additional information, see the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

To the extent that health centers receive non-monetary donations, the current rules apply for counting the estimated reasonable acquisition cost of donations on Table 8A, as specified in the UDS Manual (PDF - 1.9 MB).

(Added: 5/14/2020)

Health Center Program awardees should report the following COVID-19 supplemental funding on new, designated lines within UDS Table 9E:

• Coronavirus Preparedness and Response Supplemental Appropriations Act (activity code H8C) on Line 1l.
• Coronavirus Aid, Relief, and Economic Security (CARES) Act (activity code H8D) on Line 1m.
• Expanding Capacity for Coronavirus Testing (activity code ECT) on Line 1n.

Table 9D, Line 8c should be used to reflect charges, collections, and adjustments associated with testing and treatment of uninsured patients with suspected or diagnosed COVID-19. Table 9E, Line 3b should be used to reflect funds received through the Provider Relief Fund. For additional information, see the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

Losses themselves are not directly reported as a line item in the UDS report, but will be observable through comparisons with other financial data reported. For HRSA guidance regarding lost revenue, refer to the Coronavirus-Related Funding Frequently Asked Questions (FAQ).

(Added: 5/14/2020)

BPHC recognizes the essential work (providing testing and care for those directly affected by the virus) being performed by health centers during the COVID-19 pandemic, while implementing steps to continue to provide routine, preventive, and chronic disease care to patients. We recommend you document as much information in your systems as possible, and then work with your Health Center Program UDS Reviewer during the 2020 UDS data reporting and review period to help explain any changes resulting from the pandemic. For additional information, see the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

Countable patient visits, for the purposes of UDS reporting, are documented individual, face-to-face or virtual contacts between a patient and a licensed or credentialed provider who exercises independent, professional judgment in providing services. Countable patients are those that receive at least one such visit during the reporting year.

If an individual is screened, or tested (i.e., a specimen is collected) for COVID-19, and there is no follow-up treatment provided by the health center, then this patient and visit are not counted in the annual UDS patient and visit tables. A test or screening alone does not count as a UDS visit.

If the health center provides an individual with additional services that meet the criteria mentioned above (see also page 22 of the UDS Manual (PDF - 1.9 MB)), that individual is considered a patient for UDS reporting. Their visit and the associated care would be reported in the 2020 UDS.

For UDS reporting, virtual visits are those that use interactive, synchronous audio and/or video telecommunication systems permitting real-time communication between a provider and a patient. With the Centers for Medicare & Medicaid Services expansion of telehealth, virtual visits may now be conducted with a patient in any location – including the patient’s home – for the duration of the COVID-19 public health emergency. If a virtual visit meets the criteria listed above, it is countable for purposes of UDS reporting. Virtual check-ins, used to determine whether an established patient requires a visit, and e-visits, which are portal communications with established patients, would not be counted for UDS reporting.

For additional information, see the UDS Novel Coronavirus (COVID-19) Reporting webpage.

(Updated: 11/4/2020)

The Accreditation Association for Ambulatory Health Care (AAAHC) and The Joint Commission (TJC) will keep health centers apprised of changes to the current guidance and impacts to their accreditation. If TJC is your accrediting body, please contact Brittnay Hull, TJC account executive, at (630) 792-5216 or bhull@jointcommission.org with specific questions. If AAAHC is your accrediting body, please contact Mona Sweeney, AAAHC Assistant Director of Accreditation Services, at (847) 324-7487 or msweeney@aaahc.org with specific questions.

If you need additional support or have any concerns with your accreditation and PCMH recognition (TJC, AAAHC, or National Committee for Quality Assurance) please reach out to the HRSA APCMH Initiative and you will receive a response within 24 hours. To make sure you receive the response, please add “BPHCAnswers@hrsa.gov” to your address book.

(Added: 3/24/2020)

AAAHC has resumed survey activities while following COVID-19 precautions. Prior to their survey, each health center should conduct an internal gap analysis to evaluate their readiness and implement an action plan to address any gaps. Please visit the AAAHC website  for further updates and additional resources.

TJC and Joint Commission Resources (JCR) resumed regular surveys in late July. Both TJC and JCR review the location for each upcoming survey to determine if conducting a survey at that time would be considered safe for both the client and the assigned consultants. Decisions regarding readiness are made in consultation with health centers. TJC and JCR will follow all COVID-19 infection control guidelines as well as leverage virtual capability to maximize support opportunities. Please contact TJC with questions .

(Updated: 7/28/2020)

AAAHC, TJC, and NCQA are supporting health centers affected by survey postponements, assessing each health center’s circumstances as surveys resume, and in some cases will consider providing extensions to health centers, if necessary. Any health center that has an upcoming expiration date is required to submit a Notice of Intent to HRSA.

Health centers accredited or recognized by AAAHC must also submit an application to AAAHC in order to maintain accreditation or recognition during any state or federal closure. If a survey cannot be conducted due to a state or federal emergency, accreditation and/or recognition will remain valid until a survey can be conducted, provided steps are taken to arrange for a survey within a reasonable timeframe after reopening. As always, please notify AAAHC of any significant organizational changes such as closure.

NCQA is working with health centers that received a 60-day extension due to COVID-19. HRSA will be revisiting and providing additional support to health centers with later expiration dates that are affected by the pandemic. Health centers transitioning to the 2017 standards will be contacted by NCQA six months before their expiration date to provide guidance.

If a health center chooses to continue to pursue PCMH recognition at this time and is actively undergoing check-ins, they are able to show evidence from any time in the past year. Even if requirements are temporarily not completed according to policy, the health center may still show the policy was routinely implemented before this time.

Health centers should coordinate with their respective accreditation/recognition organizations to ensure they have the most accurate information regarding expiration dates and requirements for renewal.

(Updated: 8/31/2020)

PCA and NTTAP awardees are encouraged to reach out to their Project Officer to discuss any impact to their approved work plans. Changes to the work plan will be considered on a case-by-case basis. If changes need to be made, your Project Officer will send a Request for Information (RFI) through the EHBs for you to outline and provide a detailed description of any new activities you intend to modify or propose. If changes will require a budget revision, please work with you Project Officer to determine the appropriate steps.

(Added: 3/24/2020)

The National Association of Community Health Centers (NACHC), a HRSA-supported NTTAP, maintains an online repository with up-to-date training and technical assistance resources produced by federal and non-federal entities. The Health Center Resource Clearinghouse  is a centralized hub populated with materials developed by all HRSA-funded NTTAP entities, national organizations, and government agencies on emerging issues  including COVID-19. Health centers, PCAs, and other entities can also visit the Clearinghouse for upcoming events and webinars on COVID-19.

(Added: 3/24/2020)

As part of their ongoing health education services, health centers can and should inform and raise awareness among their patients and the community of COVID-19 preventive measures; how to recognize symptoms of COVID-19 infection; and what to do if and when they or a member of their family gets sick. Health centers should provide information in a culturally appropriate manner to accommodate people with limited English proficiency. School-based health centers should participate with school administrations in educating students and parents about COVID-19 and appropriate preventive and treatment measures.

Up-to-date information about COVID-19 symptoms, prevention, and treatment is available from the CDC, including resources in multiple languages.

(Updated: 7/17/2020)

PCAs can facilitate the sharing of important information with health centers through electronic alerts, can conduct outreach to increase awareness and participation in various regional/state pandemic planning and response activities, and can learn from the health centers what issues they face and what assistance may be needed.

PCAs have established mechanisms to engage with health centers in collecting critical information during and after an emergency situation. In addition, PCAs can work to ensure that health centers are included in COVID-19 response plans by tapping into regional/state pandemic planning and response activities. Many PCAs play active roles in the state as coordinators, managers, and disseminators of real-time information during emergencies. For information on how to coordinate with officials in your state regarding the state’s emergency preparedness or pandemic plan for the COVID-19 public health emergency, PCAs can help identify the appropriate state point of contact. For questions about Medicare emergency preparedness requirements, PCAs may also contact the applicable state survey agency for guidance or assistance.

To inform HRSA’s COVID-19 emergency response efforts, PCAs are expected to regularly communicate with and encourage health centers to complete the health center COVID-19 weekly surveys. HRSA shares national and state-level COVID-19 survey data summary reports with each PCA to support targeted technical assistance to the health centers in each state. In addition, HRSA is asking each PCA to complete a separate biweekly survey (formerly weekly) to gather information on state and/or regional COVID-19 related issues.

(Updated 12/17/2020)

HCCNs have established platforms to engage with health centers to collect critical information during and after emergency situations, such as the COVID-19 pandemic. HCCNs can:

• Facilitate important and timely information sharing with health centers through electronic alerts;
• Assist health centers considering the expansion of telehealth services;
• Conduct outreach with health centers in their networks to increase awareness of the benefits of telehealth, and share challenges and lessons learned amongst health centers; and
• Work to ensure that health centers are integrated in regional and state COVID-19 response plans by coordinating with Primary Care Associations (PCAs) on planning and response activities.

Additionally, HCCNs coordinate with the Office of the National Coordinator for Health Information Technology (ONC), the Centers for Medicare and Medicaid Services (CMS), the Health Information and Technology, Evaluation and Quality (HITEQ) Center, and HRSA’s Federal Office of Rural Health Policy (FORHP) to provide training and technical assistance on hardware and/or software, provider education, workflows, patient education, billing and coding, cybersecurity, remote provider education, and policy interpretation.

(Updated: 7/17/2020)

Health centers provide comprehensive services to address the unique health needs of their target population, as well as supportive and enabling services that promote access and quality of care—such as translation, case management, outreach, patient education, and transportation. These services are even more critical for at-risk, vulnerable populations during emergencies.

Health centers may employ and intensify existing outreach services to ensure that the needs of their target populations are being addressed as appropriate. Mobile vans and temporary locations could be established for education and treatment services. Health centers that serve special populations routinely deliver services in areas where these patients live and/or work.

Health centers should work with their Primary Care Associations, National Training and Technical Assistance Partners, and Health Center Controlled Networks for technical assistance resources and best practices to support special population needs during the COVID-19 pandemic.

(Updated: 7/17/2020)

HRSA is asking health centers and Health Center Program look-alikes to fill out a weekly survey to help track the number of patients who have undergone COVID-19 testing, along with other critical information about clinic operations during the pandemic. Each health center and look-alike will receive an electronic survey on Friday afternoons from BPHCanswers@hrsa.gov. The surveys will reduce the need for other methods of information collection around COVID-19.

A COVID-19 Data Collection Survey Tool User Guide is available to assist you in completing the survey. If you have additional questions, please contact Health Center Program Support online  and select "Coronavirus Inquiries (COVID-19)" as the issue type – the third option on the “Health Center or EHBs Question” screen. You can also call Health Center Program Support at 877-464-4772, option 2, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays).

(Updated: 6/9/2020)

Please report on your experiences from the past week. For more detailed instructions, see the COVID-19 Data Collection Survey Tool User Guide.

(Updated: 7/28/2020)

The survey is sent to the Project Director listed in EHBs, but that person can also forward their unique link to anyone in the organization who can report. If you need to add additional points of contact to the survey, please reach out to Health Center Program Support online   and select "Coronavirus Inquiries (COVID-19)" as the issue type—the third option on the "Health Center or EHBs Question" screen. You can also call at 877-464-4772, 7:00 a.m. to 8:00 p.m. ET, Monday-Friday (except federal holidays).

(Updated: 4/8/2020)

The information collection surveys are open Friday afternoons through Tuesdays at 11:59 p.m. ET. If you miss a deadline, please wait until the next survey – and remember to report information for that week only.

(Updated: 7/28/2020)

Yes. The survey includes an opportunity to provide additional information, comments, or challenges you are experiencing due to COVID-19.

(Updated: 4/8/2020)

HRSA will use the information collected from the Health Center COVID-19 Survey to help track health center and look-alike capacity and the impact of COVID-19 on operations, patients, and staff, and to better understand training and technical assistance, funding, and other resource needs. HRSA will share this information with other agencies and partners.

(Updated: 7/28/2020)

The COVID-19 pandemic is a continually evolving situation. Therefore, how long HRSA will collect this information is yet to be determined. HRSA will continue to assess the situation and evaluate the information collected, and we will make adjustments as appropriate.

(Updated: 7/28/2020)

PCAs are expected to regularly communicate with and encourage health centers in completing the COVID-19 surveys. HRSA will collect and share national and state-level COVID-19 data summary reports with each PCA to support targeted technical assistance to the health centers in each state.

In addition, HRSA is asking each PCA to complete a separate, weekly online survey to gather information on state-based COVID-19 related issues, challenges, other surveillance information, and PCA/health center needs. These surveys will increase information sharing between health centers, PCAs, and HRSA in order to better support COVID-19 emergency response efforts.

(Updated: 4/8/2020)