Wednesday, November 30 2022


The federal government is seeking comments on proposed directions for Federally Licensed Health Centers (FQHCs) that provide services via telehealth. The guidelines communicate key criteria to ensure that services provided via telehealth remain within the health facility’s Health Resources and Services Administration (HRSA)-approved plan, and are therefore eligible for benefits such as Federal Tort Claims Act (FTCA) coverage, reduced 340B drug prices, and improved Medicare and Medicaid reimbursement.

The proposed guidance was released for comment on September 15, 2022 by HRSA, the component of the U.S. Department of Health and Human Services (DHHS) that oversees health centers. The guidelines apply to FQHCs that receive federal grants under the Public Health Services Act, as well as similar FQHCs that meet HRSA requirements but do not receive federal grants. Comments are due by November 14, 2022.

Existing health center program requirements apply to telehealth services

The proposed guidance outlines the HRSA’s view that telehealth is a means of delivering healthcare services to patients using telecommunications technology or equipment. Since telehealth is not considered a type of service, it does not need to be approved by an HRSA project manager from the FQHC and listed on the Form 5A. However, the proposed guidance emphasizes that all existing health center program requirements apply when services are delivered via telehealth.

Many of the requirements listed in the proposed guidance could be implemented through appropriate policies and procedures. For example, health centers using telehealth should delineate key roles and responsibilities of health center staff, such as the responsibility to obtain informed consent from patients to receive telehealth services, and the responsibility to inform patients the possibility of refusing to receive services via telehealth. Health centers should also ensure that they can charge and apply variable fee discounts to patients receiving telehealth care, and comply with all relevant licensure and scope of practice rules. .

Regulatory hurdles pose challenges for delivering telehealth services to geographically distant patients

The proposed guidelines specify that FQHCs must ensure that patients who receive telehealth services have reasonable access to the full range of health center services for telehealth care to fall within the scope of the HRSA-approved project. . This requirement potentially increases complexity for FQHCs interested in providing services in geographic areas where they do not have a physical presence.

This problem is exacerbated by the rule in the proposed guidelines that telehealth services will only be considered within the project scope of an FQHC when provided to patients who have previously presented for care in a health center or who meet a detailed set of criteria, including a requirement to be physically located within the service area of ​​the health center. This restriction severely limits an FQHC’s ability to provide in-scope services to a geographically remote patient, even if the FQHC has particular expertise in providing care for the patient’s medical condition or community. particular.

FQHCs can contract telehealth services

The proposed guidelines do not specifically address contracting for telehealth services, leaving the regular HRSA guidelines on contracting FQHC unchanged. Partnering with a local health center can offer a viable alternative for a geographically distant FQHC to leverage their specialized expertise to reach new patients via technology without losing the benefits of FQHC status.

If you would like to submit comments on HRSA’s proposed guidelines for health centers providing services via telehealth, please contact the author, your Foley Relationship Partner, or our Healthcare Practice Group with any questions.

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