The Health Centers Consolidation Act and associated regulations lay out minimum requirements for qualification as a FQHC. These qualifications include issues of governance, populations to be served, services provided and administrative reporting requirements. Each of these requirements is described in greater detail below.
Service and operational requirements. FQHCs must provide services to underserved populations or be located in a medically underserved area (MUA) as designated by HHS and provide services to all residents within that area without regard to income or insurance status. They are also required to provide comprehensive primary care and ancillary services including clinical care by physicians and nurses; diagnostic laboratory and radiology services; perinatal services; immunizations; well-child exams; pediatric eye, ear and dental screening; family planning; and, pharmacy services. Finally, FQHCs are required to maximize patient payments (using an income-based sliding fee schedule) and third party payments, using the Section 330 grant, only to cover deficits after other sources of funding have been exhausted.
Health center governance. In addition to the basic requirements described above, CHCs, like all FQHCs, are subject to federally defined governance requirements. Specifically, HRSA rules require full authority and oversight responsibility for the center to rest with a governing board of 9-25 members, the majority of whom must have actually used clinic services in the last two years or be the legal guardians of CHC clients. Non-client members must represent the area served by the center and have expertise in community affairs. Half of these non-client members cannot earn more than 20 percent of their income from the health care industry and, overall, board members must demographically reflect the group of individuals served by the center. Finally, center staff and their spouses are not eligible for the governing board. Board responsibilities include meeting at least once a month, selecting the services to be provided by the center, scheduling the hours during which services will be provided, approving the center’s budget and leadership and establishing general policies for the center.
Reporting requirements. CHCs are required to annually submit data to the national Uniform Data System (UDS). Data for this annual submission includes basic information on the center finances, staffing and resources as well as encounter and patient based information. The list of items for submission includes:
- contact information for center grantee and service delivery sites;
- services offered and delivery methods;
- center staffing;
- encounter based information including frequency of selected diagnoses and utilization of selected services (e.g., pregnancy and prenatal care, mental health services, etc.);
- demographic information on health center users including age, gender, race/ethnicity, languages spoken, socioeconomic characteristics and insurance status; and
- center revenues broken out by patient related revenue (managed care and non-managed care) and other sources of revenue
Because centers are required to provide these data electronically, the ability to accurately and efficiently manage this information is an important feature of CHC information systems. In addition to federal reporting requirements related to the UDS, many CHCs fulfill requirements for accreditation by the Joint Commission on the Accreditation of Health Care Organizations (JCAHO).