COMMON HRSA COMPLIANCE QUESTIONS: Required and Additional Services – Form 5A, Bus Tokens

For the next post in our series covering common HRSA compliance questions we will look at the required service of “Transportation Services”. The HRSA Form 5A Service Descriptors document states that, “Transportation services are services that enable patients to access health center services when transportation would otherwise be a barrier to care (e.g., providing transport vans, bus tokens or vouchers for public transportation, or linkages to other community transportation programs)” (HRSA Form 5A Service Descriptors).

There is variation among Project Officers and consultants on how health center services should be documented (Column I versus Column II) if the health center is purchasing and providing bus/taxi vouchers/tokens to their patients.

Arguments for Column I:

  • The health center employee handing the transportation voucher to the patient is a W-2 employee.
  • This service that this health center employee is providing is in fact, “enabling patients to access health centers services when transportation would otherwise be a barrier to care”.
  • The health center is paying for the voucher.

Arguments for Column II:

  • The person actually providing the service (bus/taxi driver) is not a W-2 employee of the health center.
  • The health center (W-2) employee is not directly providing the service.
  • The health center is paying for the voucher.

The HRSA Site Visit Protocol states that, “For purposes of the HRSA-approved scope of project (Form 5A: Services Provided), HRSA/BPHC utilizes Internal Revenue Service (IRS definitions to differentiate contractors and employees. Typically, an employee receives a salary on a regular basis and a W-2 from the health center with applicable taxes and benefit contributions withheld.” (HRSA Site Visit Protocol, p. 11)

Health centers have not received clarification on this issue so it is important for leaders preparing for their next HRSA Operational Site Visit to discuss with their Project Officer ahead of time and review their HRSA Form 5A in detail to ensure they have clarity on how their Required and Additional Services are documented. Whether your team performs a health center mock site visit or reviews the HRSA Program Requirements themselves, health center teams should know the different views on these services and prepare to confidently defend the way they have chosen to document the services. Continue to reference both the HRSA Compliance Manual and the HRSA Site Visit Protocol to remain up-to-date with the most recent changes in HRSA Compliance and health center program requirements.