Section 330 Health Center Program Toolkit

Community health centers are subject to a myriad of programmatic requirements, as set forth in Section 330 of the Public Health Service Act, its implementing regulations, and guidance issued by the Health Resources and Services Administration (HRSA).  

In recent years, HRSA significantly expanded its oversight and monitoring of health centers. In addition to implementing formalized operational site visits, HRSA established a process to address findings of non-compliance, commonly referred to as the “progressive action process.” 

Most health center programmatic requirements are now consolidated in two main resources:

  • Health Center Program Compliance Manual: a consolidated resource to assist health centers in understanding, demonstrating, and operationalizing compliance; and
  • Site Visit Protocol: an objective assessment tool that aligns with the Manual and is used by HRSA for on-site reviews and desk audits of project and designation renewal applications.

The Section 330 Health Center Program Toolkit is designed to help health centers in understanding and responding to key compliance issues related to HRSA’s programmatic requirements. Our Toolkit includes checklists and sample policies, including:

  • Sliding Fee Discount Program and Related Billing and Collections Checklist
  • Referral Agreement Checklist
  • Purchase of Services Agreement Checklist
  • Bylaws Checklist
  • Sample Procurement Policy

The Toolkit also highlights key scope of project considerations and summarizes requirements applicable to the governing body’s composition and authorities.

View the Table of Contents on the Agenda tab.

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    Section 330 Health Center Program Toolkit

    Table of Contents

    I. HRSA Programmatic Compliance: Guidance
    • Section 330 Program: Compliance Overview
      • Key Requirements
      • Health Center Program Compliance Manual
      • Operational Site Visits and Progressive Action Process
      • Areas of Focus
      • Frequently Asked Questions
    • Scope of Project: Key Considerations
    • Governing Board: Key Considerations
    II. HRSA Programmatic Compliance: Resources
    • Sliding Fee Discount Program and Related Billing and Collections: Checklist
    • Purchase of Services Agreement: Checklist
    • Referral Agreement: Checklist
    • Health Center Bylaws: Checklist
    • Quality Improvement / Assurance System: Checklist
    • Credentialing & Privileging Program: Checklist
    • OSV Preparation: Sample Questions for the Governing Board 
    • Sample Position Description: Health Center Governing Board
    III. Federal Grant Management: Recommended Policies
    • Health Center Grant Management: Introductory Guidance
    • Uniform Grants Guidance: List of Required Policies
    • Financial Management Policy: Sample (including a written Cost Allocation Plan)
    • Procurement Policy and Procedures: Sample
      • Purchase Request: Sample
      • Procurement Planning Form: Sample
      • Procurement Record Form: Sample
    • Property Management Policy: Sample
    • Subaward (Subrecipient) Risk Assessment and Monitoring Policy: Sample
    IV. Federal Grant Management: Additional Tools
    • RFP for Audit Services: Sample
    • Subaward (Subrecipient) Agreement Drafting: Key Considerations
    • Subaward (Subrecipient) Monitoring Plan: Sample
    V. HRSA Resources and Links
    • Form 5A: Service Descriptors for Services Provided
    • Form 5A: Service Delivery Method (Column) Descriptors
    • Form 5A: Updating Services Provided
    • Form 5A: Scope Adjustment Questions
    • Add a New Service to Scope
    • Delete Existing Service from Scope
    • Form 5B: Instructions
    • Form 5B: Recording Suites, Floors, or Buildings
    • Form 5B: Scope Adjustment Questions
    • Add New Service Site
    • Delete Existing Service Delivery Site


    This Toolkit and its resources were created in response to requests from health centers across the country for assistance understanding HRSA guidance and complying with Section 330 programmatic requirements. Attorneys from Feldesman Leifer LLP routinely help health centers prepare for operational site visits and other on-site assessments to avoid potential grant conditions and funding restrictions or to properly respond to stated government concerns. We assist organizations in ongoing compliance efforts through appropriate contracting, improved policies and procedures, and trainings, informed by decades of experience advising federally qualified health centers, behavioral health providers, primary care associations, and health-center controlled networks.


    A Partner in the firm’s health care practice group, Molly advises health centers on the management of clinical, employment and workforce-related risks, with a particular focus on professional liability, the Federal Tort Claims Act, and HIPAA matters. From her experience as both a private attorney and in-house counsel, Molly knows the importance of managing liability and risk issues in mission-driven organizations. [Full Bio]


    Carrie Bill Riley is a Partner in the health care, non-profit and corporate law, and federal grants law practice groups. She counsels a wide variety of health care clients, including Federally Qualified Health Centers and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on  transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. [Full Bio]


    A Partner with the firm in the federal grants and health care practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law.  Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]


    A Partner at the firm, Marcie specializes in health care law, particularly in the areas of federal grants, grant-related requirements and grants management related to the federal health center program. Health centers turn to Marcie as a resource for knowing not only the letter of the law, but also the likely interpretation of requirements by federal policymakers, including the Health Resources and Services Administration (HRSA). [Full Bio]


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    Purchasing this Toolkit provides access for one calendar year. This access includes any updates or additions Feldesman Training Solutions makes to Toolkit resources throughout the year at no extra charge.


    We only allow health centers to purchase this Toolkit. As a result, we must review and approve all purchases to verify eligibility. We review and approve orders as quickly as possible, but there are occasional delays. Please allow up to 3-5 business days for approval.

    PCAs, HCCNs, and other membership organizations interested in purchasing Toolkit subscriptions for their health center members should Contact Us for pricing options.


    By purchasing this Toolkit, you acknowledge and agree to our Terms of Use and Privacy Policy. This Toolkit has been prepared by attorneys at Feldesman Leifer LLP (Feldesman) and includes original materials developed by Feldesman. This Toolkit is designed as a resource and the materials are not intended to be adopted word for word; Feldesman recommends that each organization tailor the materials to fit your health center's legal, financial, administrative, and programmatic needs. Failing to modify the original materials to the specific needs of your program may have adverse consequences. 

    By purchasing this Toolkit, you acknowledge and agree that the materials contained herein do not constitute legal advice and your purchase does not create an attorney-client relationship between you and Feldesman, nor is it intended to do so. If legal advice or other expert assistance is required, your organization should enter into an engagement agreement with Feldesman or seek the services of another competent professional. Each legal problem is different, and past performance does not guarantee future results.

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