HRSA Clarifies Public Agency Status under the Health Center Program – NAPH Requests Input - September 1, 2009

HRSA has issued a draft Policy Information Notice (PIN) limiting the organizations eligible to qualify as public agencies for the purpose of meeting Section 330 grant or Federally Qualified Health Center (FQHC) Look-Alike requirements. Such agencies are permitted flexibility to satisfy governing board composition and other requirements through a “co-applicant” arrangement. Under the draft notice, HRSA will assess public agency status using an IRS letter ruling, or other supporting documentation, “demonstrating that the entity is a subdivision, municipality, or instrumentality of government that is exempt under Internal Revenue Code section 115.” Existing centers that no longer qualify as public entities will be required to come into compliance with governance and other FQHC requirements. To determine the need to submit comments—which are due October 13, 2009—NAPH is soliciting feedback about the potential impact of this notice. Please send your responses to Claudine Swartz at cswartz@naph.org.