Don’t Fall for Scare Tactics: a FQHC Does Not Require Extra Needs Assessment


Like many types of businesses, there are consultants and companies who offer services to health centers. Some consultants may try to convince health centers that they need an extra needs assessment: don’t fall for their scare tactics! The needs assessment that a FQHC completes for a Service Area Competition (SAC), New Access Point (NAP), Look-alike Designation, or Look-alike Recertification must meet the compliance requirements for a health center but the basic requirements under the new compliance guide are not new. As always, the needs assessment should assess the need for health services in the service area you intend to serve. The rest of your application must show how your health center’s services meet the health care needs of the population served or proposed to be served.

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Use Your Board Meeting Minutes to Reflect Compliance with Health Center Program Requirements for Board Authority

Health Center Program Requirements

Health Centers are required to have a board with at least nine and no more than 25 members with a patient majority of at least 51 percent. The patient members must be a reasonable representation of the people who seek and receive health services at the clinic in terms of the demographic attributes identified in the health center’s Uniform Data System (UDS) reporting. Non-patient board members must be representative of the community in which the health center is located; this can be met with individuals who live, work or have some other type of identifiable connection to the community.

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Board-Approved Policies Needed to Demonstrate Health Center Program Compliance

Health Center Program

Board members of Health Center Program participants play a big role in the success of the health center by providing leadership and oversight to ensure that underserved community members have access to health care services. Challenges and opportunities are addressed while meeting the HRSA health center program requirements for health centers. One of the ways that board members meet HRSA requirements is by approving board policies that demonstrate compliance with the health center program.

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How to Speed up the FQHC Look-alike Application Process

FQHC Look-alike

It’s not clear when there will be any New Access Point (NAP) funding in the federal budget.  With the uncertainty of funding availability, another option for stabilizing your health clinic is to consider becoming a Federally Qualified Health Center (FQHC) Look-alike.

Becoming a FQHC Look-alike can take 12-15 months, but with expert assistance, Look-alike status may be granted in less time. One of the best ways to speed up the application process is to minimize the need to resubmit documents and other elements of the application by having an experienced consultant and health center grant writer develop a work plan that addresses the 19 program requirements and guides the health clinic through the process.

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Get the Best Possible Letter of Support for your Health Center Grant Application

Letter of support

A Health Center Program Grantee is a community health center (CHC) that receives grant funding from the Health Resources and Services Administration (HRSA) Bureau of Primary Health Care, under the Health Center Program. In order to become a grantee, CHCs must submit a successful grant application. Applications must include “letters of support” from other health care providers and potential community partners. Specifically, CHCs must have letters of support from other Federally Qualified Health Centers (FQHCs), FQHC Look-alikes, critical access hospitals, and local and state public health jurisdictions located in the area they serve. CHCs serving special populations (migrant seasonal agricultural workers, people who are homeless and residents of public housing) must have letters from organizations that also serve those populations.

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Why are FQHC Look-alikes Required to Obtain 501(c)(3) Status?

501(c)(3) status

In order for a Community Health Center to become a FQHC Look-alike, the organization must first apply for and be designated  nonprofit  501(c)(3) status by the Internal Revenue Service (IRS). This is not a requirement of the Bureau of Primary Health Care; it is a Medicare requirement.  In order to complete an application for Medicare reimbursements, Medicare mandates all nonprofit organizations show proof of 501(c)(3) status.

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Get a Jump Start on the Needs Assessment for your SAC or OSV

needs assessment

In order to receive (and maintain) grant money as a Federally Qualified Health Center (FQHC), community health centers (CHC) must meet 19 Program Requirements. PR #1 requires health centers to document an assessment of the needs of the target population. For health organizations considering becoming an FQHC or FQHC Look-alike, one of the first steps is completing a needs assessment. Unlike the community health assessments frequently done by local hospitals and public health jurisdictions, a health center needs assessment must address a specific set of questions. These same questions are addressed in the Service Area Competition (SAC) and New Access Point (NAP) grants.

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Get your Community Health Center Ready for your next Big Federal Grant or Operational Site Visit

There is a list of 19 Health Center Program Requirements (PRs) that a community health center (CHC) must meet during an Operational Site Visit (OSV). The purpose of an OSV is to verify compliance with the requirements. Two of the requirements that cause trouble for many health centers is PR #2 Required & Additional Services and PR #16 Scope of Project both of which involve services you provide through contract or formal written referral agreements.  Annually you should schedule a time to look over and update your contracts to ensure that they meet program requirements.

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Timeline to Become a FQHC Look-Alike

FQHC Look-Alike

A FQHC (Federally Qualified Health Center) Look-alike is a health center that meets all Health Center Program requirements and is part of the Health Center Program but does not receive federal award funding. Having Look-alike status does provide several important benefits, however, including access to FQHC Prospective Payment System reimbursement methodologies for services provided to Medicare and Medicaid beneficiaries and discounts on pharmaceutical drugs through the 340B Federal Drug Pricing Program.

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