Centers undergoing the Health Resources and Services Administration (HRSA) operational site visits in the last couple of years have come to dread the Form 5A: Services Provided analysis. Centers have experienced such difficulty with this form, it has been dubbed the “universal fail.” Form 5A is arguably the most subjective of the review process. However, when centers review and understand what the form means for them the review process goes much smoother.
Let us clarify some terms.
Scope: The scope of a project defines the approved service sites, services offered at that site, providers on-site, service area(s) for the site, and target population(s) that are supported (wholly or in part) under the total Section 330 grant-related project budget. A grantee’s scope of project must be consistent with applicable statutory and regulatory requirements, health center program requirements, and the mission of the health center.
Services: Health centers are required to provide a set of primary health care services (e.g., required services) described in statute and regulations. Centers also may provide additional health services, as appropriate to meet the needs of the population served by the health center, including certain specialty services.
Services can be provided one of three ways as described in Column I, II, or III. Column I services are those provided by the center directly. Column II services are provided through a formal arrangement where the center pays for the service. Column III services are those provided through a third party where the center does not pay. Formal agreements supporting Column II, or III services must include specific language. For example, a Column II agreement must describe how the center will pay for services and ensure all medical records will be provided for inclusion in the medical record. Column III agreements must ensure that all patients will be seen regardless of their ability to pay and be offered a sliding fee that is better or equal to the centers.
Centers must also ensure that services are provided in a culturally and linguistically appropriate manner based on the target population(s). In assuring that services are appropriate for the needs of the patient population served, the health center must take reasonable steps to provide meaningful access to health center services for patients with limited English proficiency.
The most important tool for assessing compliance is the Service Descriptors for Form 5A: Services Provided document. Service Descriptors for Form 5A: Services Provided document(hrsa.gov) This document defines what it means to provide both required and additional services. Helping centers understand what the definitions are, and how this works in their system is critical. Each category (general primary medical care, diagnostic laboratory etc.) has a specific definition. The definition clarifies what the center must do in provision of the specific service, and what the center may do. For example, it is not uncommon for a center to think they have to provide invasive dental care as a minimum requirement. However, the requirement is only provision of basic dental screenings, oral hygiene instruction, oral prophylaxis, and topical application of fluorides.
HRSA has provided centers a tool for internal review of their Form 5A Health Center Self-Assessment Worksheet for Form 5A: Services Provided (hrsa.gov). Although this tool is helpful, without the service descriptors, centers remain confused about how to accurately assess their form.
Form 5A can be frustrating, confusing, and subjective. However, it is a critical form for it drives not only scope, but FTCA coverage as well. Taking the time to review, together with the service descriptors, offers centers the opportunity to ensure they are providing both required and additional services in the appropriate manner for their protection as well as delivering comprehensive care to patients.
"For more information on how to conquer your Form 5A, email us at www.contactus@renayejames.com or visit our website at www.renayejames.com"
Dr. Elizabeth Latham is a seasoned organizational leader having attained significant applied clinical and healthcare organizational expertise. She is a subject matter expert for the Health Resources and Services Administration (HRSA) Operational Site Visits (OSVs) and has assisted federally qualified health centers to achieve compliance with the Health Center Compliance Manual.