HRSA Provides Additional FAQs on COVID-19
Providing Care During Emergencies
Do health centers offer testing for COVID-19? (Added: 3/15/2020)
Health centers are an important component of the national response to the COVID-19 virus. Call your nearest health center to find out the availability of COVID-19 screening and testing. Health Centers can assess whether a patient needs further testing, which may be done over the phone or using telehealth. Individuals may also receive primary health care services at their local health center at a reduced cost or free of charge depending on their economic status.
What are the requirements for FTCA in light of the declaration of a national public health emergency? (Added: 3/15/2020)
The Secretary of Health and Human Services, Alex Azar, on January 31, 2020, issued a declaration of a national public health emergency regarding the COVID-19. As detailed in Program Assistance Letter (PAL) 2014-05 (Updated Process for Requesting a Change in Scope to Add Temporary Sites in Response to Emergency Events): "HRSA recognizes that during an emergency, health centers are likely to participate in an organized State or local response and provide primary care services at temporary locations." Health centers may set up "temporary sites (that) are within the health center's service area or neighboring counties, parishes, or other political subdivisions adjacent to the health center's service area" (for in-scope services) with notification made to BPHC within 15 days. Please see PAL 2014-05 (PDF – 200 kb) for full details and requirements “to ensure that the emergency response at temporary locations is considered part of the center's scope of project."
For purposes of FTCA coverage, patients served by covered individuals at temporary locations included in the covered entity's scope of project are considered the covered entity's patients. As such, the covered entity and its providers are covered by FTCA for services provided during the emergency at temporary locations." (See the FTCA Health Center Policy Manual (PDF – 408 kb) Section F: A record of the services provided for each patient should be maintained.)
In addition, please see: Section (I) C.3 of the FTCA Health Center Policy Manual (PDF – 408 kb), Provision of Services to Health Center Patients, which states in part: "To meet the FTCA requirement of providing services to health center patients, a patient-provider relationship must be established. For the purposes of FSHCAA/FTCA coverage, the patient-provider relationship is established when: …Health center triage services are provided by telephone or in person, even when the patient is not yet registered with the covered entity but is intended to be registered."
Please also see the FTCA Health Center Policy Manual (PDF – 408 kb) Section (I) C.4 regarding Coverage in Certain Individual Emergencies.
Additionally, please note the PAL 2017-07 (PDF – 288 kb) Temporary Privileging of Clinical Providers by Federal Tort Claims Act (FTCA) Deemed Health Centers in Response to Certain Declared Emergency Situations).
Is it acceptable to conduct a physician initial consultation with a patient via telehealth in light of COVID-19? (Added: 3/13/2020)
In light of the declaration by the Secretary of Health and Human Services on January 31, 2020, that a public health emergency exists nationwide as a result of confirmed cases of 2019 Novel Coronavirus (2019-nCoV), health center providers may provide triage services, including initial consultation, as part of primary care to patients or to individuals that intend to become a patient of the health center.
These triage services may be conducted by health center providers either in person or by telehealth, consistent with applicable standards of practice. For more information, see PAL 2020-01, Telehealth and Health Center Scope of Project (PDF – 520 kb).
What are the expectations for health centers during a disease outbreak such as COVID-19?
Health centers are expected to plan for the provision of ongoing, continuing preventive and primary care to their patients. By maintaining the ability to treat their patients, health centers can help alleviate some of the congestion of patients seeking treatment elsewhere, such as local hospital emergency departments. In many instances, health centers also coordinate with state and local health departments as part of emergency management planning, preparedness, mitigation, and response.
How can health centers participate in addressing the influx of patients that may be seeking care during a widespread outbreak of COVID-19 within their communities?
Well in advance of an emergency, health centers should establish relationships with local hospitals and other large community health care providers regarding the possible roles that health centers might perform in connection with emergency situations.
In certain circumstances, health centers are permitted to request a change in scope of project to temporarily add a location in response to emergency events. See PAL 2014-05 (PDF – 200 kb) for additional information about the requirements and process for requesting such a change in scope.
How can health centers contribute to community awareness and education to lessen the severity and impact of a COVID-19 outbreak?
As part of their ongoing health education services, health centers can and should inform and raise awareness among their patients and the community of COVID-19 preventive measures; how to recognize symptoms of COVID-19 infection; and what to do if and when they or a member of their family gets sick. Health centers should provide information in a culturally appropriate manner to accommodate people with limited English proficiency. School-based health centers should participate with school administrations in educating students and parents about COVID-19 and appropriate preventive and treatment measures.
Funding and Resources
How can health centers access the National Stockpile to get Personal Protective Equipment (PPE) and additional supplies in response to the Coronavirus? (Updated: 3/15/2020)
If a health center's regular distributors are unable to fulfill orders for critical medical supplies such as personal protective equipment, the first step is to contact your local and/or state public health department for immediate assistance. If the state is unable to provide supplies, state health officials — through the governor or his/her representative — may request federal assistance from the U.S. Department of Health and Human Services (HHS).
If assistance is approved, the HHS Assistant Secretary for Preparedness and Response will direct deployment of supplies from the SNS to state public health officials. The state is then responsible for distributing the supplies to areas in need. We understand the difficulty of this situation, but the state department of health is your best option for assistance with needed supplies. (Updated: 3/15/2020)
For New York FQHCs outside of New York City - contact your local Office of Emergency Management (you may also want to contact your county Local Department of Health for additional guidance).
For FQHCs in New York City - contact firstname.lastname@example.org
How will HRSA distribute the $100 million allotted by Congress for health centers to prepare and care for patients with suspected or confirmed COVID-19?
On March 6, the President signed into law the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, which provides $8.3 billion in emergency funding for federal agencies to respond to the COVID-19 outbreak. $100 million is available for health centers to prevent, prepare for, and respond to the COVID-19 national emergency. HRSA is working quickly to develop a spend plan and will expedite the awarding of funds.
Emergency Preparedness and Response
What are HRSA's requirements for health centers in the areas of emergency preparedness and emergency response?
Program Assistance Letter (PAL) 2014-05 (PDF – 200 kb) provides information regarding the process for requesting a change in scope to the federal scope of project to add temporary locations in response to emergency events.PAL 2017-07 (PDF – 288 kb) clarifies the credentialing and privileging documentation required to support temporary privileging of clinical providers by health centers in response to certain declared emergency situations.The Federal Tort Claims Act Health Center Policy Manual (PDF – 408 kb) in Section F: FTCA Coverage When Responding to Emergency Events provides additional guidance related to emergencies.
How can health centers prepare for a possible surge in patient load?
Health centers are encouraged to coordinate with local and regional health care providers to identify and define appropriate roles and responsibilities in the event of an emergency. For health centers that have the ability to engage in surge capacity, the considerations include: expanded hours, temporary locations, utilization of telehealth and/or medical mobile units or vans; steps for securing additional clinical personnel; and identifying sources for supplemental medical supplies, vaccines, and pharmaceuticals.