On August 11, 2026, HRSA released its new Health Center Program Scope of Project Policy Manual (the “Scope Manual”). The Scope Manual went into effect immediately.
It is critical that health centers understand the new requirements and assess how the changes impact both current and future operations. Scope of project is fundamental to the Health Center Program, defining the activities that comprise the HRSA-approved health center project.
The changes are broad and significantly impact operations. The Scope Manual adds new service site settings, introduces new standards for reviewing scope change requests, eliminates a long-standing scope form, and sets forth new geographic restrictions on the provision of services through telehealth.
Key changes/updates include that Scope Manual:
It is critical that health centers understand the new requirements and assess how the changes impact both current and future operations. Scope of project is fundamental to the Health Center Program, defining the activities that comprise the HRSA-approved health center project.
The changes are broad and significantly impact operations. The Scope Manual adds new service site settings, introduces new standards for reviewing scope change requests, eliminates a long-standing scope form, and sets forth new geographic restrictions on the provision of services through telehealth.
Key changes/updates include that Scope Manual:
- Imposes new geographic restrictions on the ability to provide services by telehealth such that the patient must either reside in or be physically located in the health center service area or areas adjacent to the service area.
- Establishes new specific factors to guide HRSA’s assessment of proposed sites and service area overlap, with an emphasis on unmet need, penetration, community input, and distance from existing health center sites.
- Replaces Column III “referral arrangements” with “cooperative arrangements” and establishes new provisions that must be in the written agreement/MOU.
- Expands the governing board’s role in scope oversight, including requiring that the board approve the methods to deliver in-scope services—directly, by contract, cooperative arrangement, or subrecipient.
- Introduces the concept of “contractor-operated” service sites and establishes requirements regarding the health center’s oversight and control and provisions that must be in the agreement.
- Introduces new “co-located” service site settings, including sites co-located with hospitals, schools, and other organizations, and establishes requirements regarding separation of health center operations and provisions that must be in a written agreement governing the arrangement.
- Eliminates Form 5C and establishes new parameters for activities outside approved service sites, including when services may be provided to individuals who are not established health center patients.
- Defines the concept of “on behalf of” the health center and emphasizes that activities must be conducted “on behalf of” the health center to be in scope, while distinguishing separate “other lines of business” that are outside the health center’s scope of project.
- Establishes that a health center must prioritize its available resources for its service area population and that a health center may choose, but is not required, to extend services to individuals who reside outside its defined service area.
Want to know more?
For more information, please contact:
Carrie Riley
carrie.riley@powerslaw.com
