Last summer, HRSA issued warning notices to health centers following review of FTCA deeming applications submitted for the CY 2026 deeming cycle, citing deficiencies in all four quarterly risk assessments. The core finding was that completed questionnaires and action item lists do not, standing alone, constitute a complete risk assessment. Instead, HRSA expects health centers to provide a detailed narrative explicitly addressing scope and focus, methodology, risk identification, risk analysis, risk evaluation, and an action plan with follow-up and monitoring components.
Notably, HRSA cautioned that when using tools such as an ECRI checklist, simply checking "yes" or "no" is insufficient; each response must be supported by notes describing the process, specific data reviewed, and any identified risks or weaknesses. With CY 2027 deeming applications due June 26, 2026, health centers should treat these warning notices as a roadmap and audit their quarterly risk assessment documentation now.
For more information, please contact:
MOLLY EVANS
molly.evans@powerslaw.com
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