Question 1

What are the 19 HRSA program requirements for FQHCs?

Accepted Answer

HRSA requires FQHCs to meet 19 program requirements covering: needs assessment, required/additional services, clinical staffing, accessible hours/locations, sliding fee scale, quality improvement/assurance, board authority, board composition, governance, financial management, billing/collections, budget, program data reporting, scope of project, federal/state requirements, health center controlled facilities, organizational structure, contracts/subawards, and conflict of interest policies. Noncompliance can result in conditions of award or loss of Section 330 funding.

Question 2

How often do FQHCs receive HRSA Operational Site Visits (OSV)?

Accepted Answer

FQHCs receive an Operational Site Visit from HRSA approximately every 3 years. The OSV reviews compliance with all 19 program requirements. FQHCs should maintain continuous readiness by conducting internal audits and keeping documentation current rather than scrambling before a scheduled visit.

Question 3

What are the HIPAA requirements for FQHCs?

Accepted Answer

FQHCs must comply with HIPAA Privacy, Security, and Breach Notification Rules including appropriate Business Associate Agreements with vendors handling PHI, an accurate and thorough security risk analysis under 45 CFR § 164.308, workforce training appropriate to role and policy, breach notifications within required timelines, and retention of HIPAA documentation for required periods. Many organizations review risk analysis and training annually, but timing should also reflect system, vendor, workflow, and material risk changes.

Question 4

Can FQHCs bill two encounters on the same day?

Accepted Answer

Under Medicare PPS, FQHCs can bill 2 encounters on the same day if the patient sees two different providers for two different services (e.g., medical + behavioral health). Under Medi-Cal, generally only 1 PPS encounter per day is allowed, though some managed care plans may allow exceptions. FQHCs cannot bill 'incident-to' like private practices.

Question 5

What is the False Claims Act penalty for FQHCs?

Accepted Answer

False Claims Act exposure can include inflation-adjusted per-claim penalties, treble damages, repayment, monitoring, and other consequences depending on the facts. Potential FQHC risk areas include unsupported billing, coding errors, documentation gaps, and 340B duplicate-discount issues. Organizations should verify current DOJ/OIG guidance and involve qualified counsel for specific matters.

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Calendario de Cumplimiento 2026

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