A change in scope for health care centers is a mini-application that health care centers must use when they are 
adding a new target population, adding a new service or service delivery site, or deleting a service or service delivery site.
Revised process for change in scope for health care centers
HRSA has recently revised the change in scope (CIS) process; narrowing the process down to four types of CIS. The changes were made as a result of feedback from health care centers and a HRSA internal review. The goals of the revised policy include a desire to increase clarity, reduce redundant information and overall to simplify the process for a health center to request changes to its scope of project.
These goals appear to have been accomplished! The new streamlined process includes:
- The removal of redundant questions about program requirements and a focus on questions that provide the actual information HRSA needs to conduct a timely review of the request.
- A revised assurances section of the checklists that clearly states the responsibilities of the health center in submitting a change in scope request. You simply agree to the assurances rather than answering the old laundry list of questions about updating your FTCA or malpractice insurance, and notifying Medicare, Medicaid, and 340B.
- The removal of financial questions about your budget. Instead you simply wait for the annual BPR or SAC application.
HRSA has also promised a streamlined internal review processes.
What is scope of project for health care centers?
A health care center’s scope of project is the activities supported by the Section 330 project budget; specifically a health center’s sites, services, service area, target population and providers.
Per 45 CFR Part 75.308, HRSA requires that health centers maintain their funded scope of project including any increases based on recent grant awards. When a health care center’s scope of project changes, they may expand with the help of new grant awards but must seek approval through a change in scope request first.
Health care centers should review their scope of project forms on a regular basis to make sure that they are up to date and still accurate. Health Center Solutions recommends you do this at least annually with your board of directors and document the process in the board meeting minutes. This allows you to easily demonstrate that your board approves your services and hours of operations.
It is also critical that health care centers follow and understand any new Policy Information Notices (PINs) and Program Assistance Letters (PALs) so they are accurately documenting their scope of project and know when to submit a change in scope request to HRSA.
How to submit a change in scope for health care centers
Change in scope requests should be submitted before adding a new service or service delivery site, deleting a service or service delivery site or adding a new target population. These requests are submitted online through electronic hand books (EHBs) at least 60 days before implementing a change.
Steps to prepare and submit a change in scope request:
1. Review sample forms and instructions on submitting change in scope requests.
2. Before getting started in the EHB filling out the forms, consult with your health center project officer on any proposed change.
3. Gather the necessary information and documentation to submit the CIS request through EHBs.
a) For all types of CIS make sure to have a copy of the signed board meeting minutes to attach.
b) When adding a site have copies of your lease agreement or title and copies of floor plans.
4. Complete and submit the official forms online through EHBs.
5. Watch for a Notice of Award (NoA) (for grantees) or a HRSA notification (for look-alikes) that will be issued once the formal change in scope request has been submitted, reviewed and approved.
6. It is up to the health center to verify in EHBs that the requested change has been implemented within 120 days of HRSA’s NoA/notification. After verifying the change has been implemented through the scope verification, the change will be officially documented in the health center’s approved scope of project.
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