In my work as an independently contracted Operational Site Visit (OSV) clinical reviewer for HRSA, I have seen different reviewers interpret HRSA requirements around documenting contracted providers differently. For example, if a health center has a locum tenens contract, they generally enter this in the “Formal Written Contract/Agreement” column on Form 5A (formerly referred to as “Column II”) under "General Primary Medical Care" services. If the locum tenens provider also provides other required services (like voluntary family planning, screenings, after-hours coverage, well-child care, case management, etc.), I have seen clinical reviewers have varying views on how health centers should document those other services. Some say that the health center should also document in Column II for every single service they provide (marking Column II for "General Primary Medical Care" and "Diagnostic Lab Services", "Screening Services", "After Hours Emergency Services", etc.). Others say that "General Primary Medical Care" is considered the umbrella service and all the other services are considered just part of providing good primary medical care (and not required to mark every service on Form 5A).
Because there is often much confusion in this area, I reached out to HRSA/BPHC in early 2026 via the BPHC Contact Form site and received the following guidance:
“The appropriate box should be checked in each service category (Column I, II, and III) for each service provided. A locum contract would be considered like any other contractor. Although the locum tenens staffing agency may only be periodically used, it is still a method in which the health center provides the services and should be recorded accordingly in Form 5A. Please review our Column Descriptors for more information on how to record items in Form 5A: https://bphc.hrsa.gov/sites/default/files/bphc/compliance/form-5a-column-descriptors.pdf.”
Though HRSA/BPHC does not plan to update the Scope Policy Manual or Site Visit Protocol with this information, they did give me permission to share this guidance publicly in an effort to have health centers and reviewers use this information to accurately document services on HRSA Form 5A. If you wish to ask additional clarifying questions about this guidance or to receive a free Form 5A evaluation from our team at RegLantern, please contact us today!
AI Disclaimer
This blog post was created 100% without the assistance of generative Artificial Intelligence (AI). It was written by a real, living (albeit fallible and quirky) human (specifically, Kyle Vath). The content is purely educational and not to be viewed as legal advice.
