1. Federally Qualified Health Center Look-Alike Program Overview and Initial Designation Application Process
Jennifer Joseph, PhD, MSEd
Chief, Strategic Operations Branch
U.S. Department of Health and Human Services
Health Resources and Services Administration
Bureau of Primary Health Care

2. Agenda FQHC Definitions, Principles, Benefits and Eligibility
Program Administration
Application Process
Application Components/Content Overview
Application Submission Information
Review Timelines
Tips for Preparing a Successful Application
Technical Assistance Resources
Questions and Answers

3. Respectively, Social Security Act §1861(aa)(4) and §1905(l)(2)(B)
What is an FQHC?
Medicare and Medicaid statutes define a provider type: “Federally Qualified Health Center” (FQHC)
Respectively, Social Security Act §1861(aa)(4) and §1905(l)(2)(B)
Entity that receives a grant under section 330 of the Public Health Service Act – Health Center Program.
Entity that is determined by DHHS to meet requirements to receive funding without actually receiving a grant (i.e., FQHC Look-Alike).
Entities that are outpatient health programs or facilities operated by a tribe or tribal organization under the Indian Self-Determination Act or by an Indian organization receiving funds under Title V of the Indian Health Care Improvement Act.

4. Fundamental Principles
Private non-profit or public entities that serve a high- need community or population
Governed by a community board of which at least a majority are health center patients who represent the patient population served
Provide comprehensive primary care and enabling and supporting services
Services are available to all, with fees adjusted based upon ability to pay
Meet all performance and accountability requirements for administrative, clinical and financial operations

5. Benefits Benefit Health Center Grantees FQHC Look-Alikes Grant funding
YES NO
Eligible for Medicaid Prospective Payment System (PPS)
Eligible for Medicare cost-based reimbursement
Access to 340B drug pricing
Eligible for Federal Tort Claims Act medical malpractice insurance
Automatic Health Professional Shortage Area (HPSA) Designation
Vaccines for Children
Eligible for supplemental HRSA funding (PCMH, capital investments, HIT incentive payments)

6. Growth of FQHC Look-Alike Program

7. Eligibility Eligibility Requirement Health Center Grantees
FQHC Look-Alikes
Must be a private, charitable, tax-exempt nonprofit organization OR public entity (direct or co-applicant arrangement).
YES
Must serve a medically underserved area (MUA) or medically underserved population (MUP) designated by DHHS.
Must not be owned, controlled or operated by another entity. NO
Must be operational and providing primary care services at the time of application submission.

8. Look-Alike Program Administration
The FQHC Look-Alike Program is operated under an intra-agency agreement between HRSA and CMS
HRSA is responsible for:
Assuring compliance with requirements under section 330 of the Public Health Service Act
Making a recommendation to CMS for designation as a Look-Alike
CMS is responsible for:
Designating an organization as a Look-Alike
This designation makes the organization eligible to apply for Medicaid and Medicare reimbursement under the FQHC payment methodologies and to enroll in the 340B drug program.

9. Program Administration
HRSA staff are responsible for:
Developing the application instructions
Providing technical assistance to applicants and existing FQHC Look-Alikes
Reviewing all initial designation, renewal of designation, and annual certification applications
Monitoring continued compliance with program requirements

10. Application Process: Grantee and Look-Alike Comparison
Health Center Grantees
FQHC Look-Alikes
Application opportunities for new organizations
New Access Point
Rolling
HRSA Electronic Handbook (EHB) application and data reporting
YES
YES, as of

11. FQHC Look-Alike Application Types
Description
Initial Designation
Comprehensive application required for organizations seeking initial FQHC Look-Alike designation
Renewal of Designation
Comprehensive application required for existing Look-Alike organizations to renew their FQHC Look-Alike designation after an initial two-year designation period, and thereafter, typically every five-years.
Annual Certification
An annual program update submitted by existing FQHC Look-Alikes.

12. Initial Designation Application Process
Application submitted
HRSA reviews for completeness and eligibility
Disapproval
HRSA reviews for compliance
HRSA sends recommendation to CMS
Request for changes and TA
CMS designates organization and informs HRSA
CMS sends recommendation to CMS regional office and State Medicaid agency
HRSA sends Notice of Look-Alike Designation
Newly designated FQHC Look-Alike applies to CMS and State Medicaid agency for FQHC Medicare and Medicaid numbers

13. Enrolling for FQHC Medicare and Medicaid Reimbursement
FQHC Look-Alike designation establishes eligibility to enroll in Medicare as an FQHC and for enrollment in State Medicaid program as an FQHC provider.
Each organization must:
Prepare and submit a Medicare Enrollment application for each permanent and seasonal site and ensure that it has received the appropriate approvals prior to billing under the FQHC benefit
Enroll in their State Medicaid program as an FQHC provider

14. Application Overview
The Initial Designation application demonstrates compliance with the requirements of section 330 of the PHS Act, including evidence that the organization:
Serves populations in high-need areas
Will maintain or increase access to primary care health services, improve health outcomes, and reduce health disparities
Provides ready access to the full range of required primary, preventive, enabling and supplemental health care services to all persons in the target population

15. Application Overview
Has a collaborative and coordinated delivery system for the provision of health care to the underserved
Has a sound and complete plan that is clearly responsive to identified health care needs of the target population
Has a reasonable and accurate budget
Is already operational and providing primary, preventive, enabling and supplemental services in the community

16. Application Components
Program Narrative
Need
Response
Collaboration
Evaluative measures
Resources/capabilities
Governance
Forms and Documents
Attachments

17. Forms and Documents Initial Designation Application Content Type
Cover Page
Form
Form 1A: General Information Worksheet
Table of Contents
Document
Project Abstract
Project Narrative
Clinical Performance Measures
Financial Performance Measures
Form 2: Staffing Profile
Form 3: Income Analysis Form
Form 3A: FQHC Look-Alike Budget
Form 4: Community Characteristics
Form 5A: Services Provided
Form 5B: Service Sites
Form 5C: Other Activities/Locations (if applicable)
Form 6A: Current Board Member Characteristics
Form 6B: Request for Waiver of Governance Requirements
Form 8: Health Center Agreements
Form 9: Need for Assistance
Form 10: Annual Emergency Preparedness and Management Report
Form 12: Contacts Information

18. Attachments Initial Designation Application Content Type
Attachment 1: Patient Origin Study
Document
Attachment 2: Service Area Map
Attachment 3: Current or Requested MUA/MUP Designation
Attachment 4: Governing Board Bylaws
Attachment 5: Governing Board Meeting Minutes
Attachment 6: Co-Applicant Agreement for Public Centers (if applicable)
Attachment 7: Affiliation, Contract, and/or Referral Agreements (if applicable)
Attachment 8: Articles of Incorporation
Attachment 9: Evidence of Non-Profit or Public Agency Status
Attachment 10: Medicare and Medicaid Provider Documentation
Attachment 11: Organizational Chart
Attachment 12: Position Descriptions for Key Personnel
Attachment 13: Resumes for Key Personnel
Attachment 14: Schedule of Discounts/Sliding Fee Scale
Attachment 15: Most Recent Independent Financial Audit
Attachment 16: Letters of Support
Attachment 17: Floor Plans
Attachment 18: Other Information

19. Application Submission
Applications must be submitted through the HRSA EHB
Refer to HRSA’s Electronic Submission User Guide, available online at for detailed application and submission instructions.
Once the Initial Designation application process is started in the EHB system, it must be completed and submitted in a maximum of 90 calendar days.
Applications that are ineligible or not completed within 90 days will not be considered for designation.

20. Registering in the EHB
Step one: Create individual system accounts for each individual who will assist in the application preparation, including the following roles: Authorizing official (AO); Business official (BO); Other employee (project directors, assistant staff)
Step two: Associate individuals with the appropriate organization.
For assistance in registering with HRSA EHBs, call GO4-HRSA ( ) or between 9:00 am to 5:30 pm ET or

21. Estimated Timelines Responsible Entity Step in Process Number of Days
Applicant
Development and submission of application once the application process has been initiated in the EHB. 90
HRSA
Initial review of the application once received in EHB.
105
Response to any follow-up information requested by HRSA. 30
HRSA review of applicant response to requested follow-up information. 45
CMS
CMS review and approval process
Estimated time from application submission to CMS approval for an application with no follow-up information requested by HRSA: Up to 135 days
Estimated time from application submission to CMS approval for an application requiring follow-up information: Up to 210 days

22. Preparing for a Successful Application
Perform a thorough needs assessment early
Request technical assistance from your PCA/PCO or other experienced health centers
Ensure that the organization is operating in full compliance with each program requirement, including active involvement and oversight of a governing board
Ensure that all application forms, attachments, and program narrative provide consistent information
Take advantage of technical assistance resources

23. Avoiding Common Mistakes
Common mistakes in applications:
Organization did not meet the eligibility requirements
Organization did not demonstrate compliance with all program requirements
Inconsistencies between the program narrative and data forms
Application did not include all required forms and attachments
Applicant did not correctly complete required forms

24. Avoiding Common Mistakes: Eligibility
Organization was owned, operated, or controlled by another entity
Organization did not have non-profit status
Organization was not serving, in whole or in part, a MUA/MUP

25. Avoiding Common Mistakes: Need
Organization’s service area was not clearly defined
Service area overlap existed with an existing FQHC
Application contained no discussion of other providers or did not include letters of support from other providers (or an explanation for why they were not included)
Application data tables did not align with the program narrative and/or organizational chart

26. Avoiding Common Mistakes: Health Services
Organization did not have after-hours coverage
Organization did not have a sliding fee scale or the sliding fee scale was not based on the most recent FPL
Organization did not have admitting privileges or document a continuity of care plan, including discharge planning

27. Avoiding Common Mistakes: Management and Finance
Organization did not comprehensively discuss lines of authority
Organization’s organizational chart lacked the names and FTEs of staff or was not aligned with the narrative
Application did not contain a recent audit
Organization did not have Medicare and Medicaid provider numbers by site to demonstrate its operational status

28. Avoiding Common Mistakes: Governance
Organization’s governing board had non-compliant bylaws
Public entity organization’s co-applicant agreement was not clearly written
Governing board bylaws did not contain a conflict of interest policy
The governing board included employees of the organization
The governing board did not meet at least monthly

29. Key Resources for Application Development
FQHC Look-Alike Application Instructions and EHB System User Guides:
Service Area Overlap: Policy and Process (PIN ) for guidance on preparing a service area overlap analysis
Health Center Program Requirements:
FQHC Look-Alike Application Resources document under “Application Help” on the TA page

30. Questions

31. Contact Information
Jennifer Joseph
Chief, Strategic Operations Branch
Telephone: