A health center’s “Scope of Project” is one of the most complex components of its Health Center Program (HCP) project – proper recording of scope is crucial in the oversight and management of all health center organizations, whether funded under Section 330 of the Public Health Service Act or designated as a Federally Qualified Health Center (FQHC) Look-Alike entity. 

In practical terms, a health center’s Scope of Project forms the framework for its entire HCP project, defining the activities supported by its program and corresponding budget, and identifying how and the extent to which programmatic requirements and essential health center benefits (e.g., Federal Tort Claims Act coverage and 340B Drug Pricing eligibility) apply. While over the years, HRSA has published numerous scope-related guidance, often these guidance documents have been “disconnected” from one another leaving health centers in the dark on how to design their Scopes of Project to best fit the needs of their organizations, patients and communities.

On August 11, 2026, the Health Resources and Services Administration (HRSA) issued its long-awaited Scope of Project Policy Manual, replacing many of the separate Scope of Project policies.  At the same time, HRSA released its responses to the comments on the draft Scope Manual, helping health centers and related stakeholders in understanding HRSA’s “thinking” regarding some of the new policies and criteria.  The new Scope Manual was effective immediately upon release, applicable to all new change in scope requests and other changes to and reviews of a health center’s scope of project.  

Join Feldesman for this one day training where we will walk through the key changes to existing Scope of Project policies and offer actionable guidance for all health centers – grantees, FQHC look-alikes, and subrecipients – regarding the implications of those changes on daily operations. Our presenters will offer practical advice and tips on demonstrating compliance with and implementation of the criteria in the new Scope Manual and the programmatic requirements that are inextricably linked to scope, assisting health centers in maintaining an effective and successful HCP project. Topics explored include:

• Determinations of when services are provided “on behalf of” the health center;
• Enhanced requirements for contracts and cooperative arrangements (formerly referral agreements) for in-scope services;
• Parameters for providing services via telehealth;
• Criteria for evaluating “service area overlap”;
• Factors for sites co-located with other organizations (including school-based health centers) and/or operated by contractors or subrecipients; and
• Revised Change in Scope processes and forms.

This one-day intensive will help you better understand the nuances of scope, the impact of the new Manual, and the difference between in-scope and out-of-scope activities, ultimately assisting in positioning your health center to design a Scope of Project that meets the needs or your organization, your patients and community.