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: Business Associate Agreements with all vendors handling PHI, annual security risk assessments (45 CFR § 164.308), workforce training within 30 days of hire and annually, breach notification to affected individuals within 60 days, and maintaining 6 years of HIPAA compliance documentation.

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

The Federal False Claims Act (31 USC § 3729-3733) imposes penalties of $13,946 to $27,894 per false claim plus treble damages (3× the overpayment). Common FQHC false claims include: billing incident-to, billing without face-to-face encounters, upcoding E/M levels, and 340B duplicate discounts. Whistleblowers receive 15-30% of recovered funds.

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