COMMON HRSA COMPLIANCE QUESTIONS: Screening Services

According to the Service Descriptors for Form 5A: Services Provided document accessed on August 26, 2019, (https://bphc.hrsa.gov/sites/default/files/bphc/programrequirements/scope/form5aservicedescriptors.pdf), “cancer screenings at a minimum must include, but are not limited to, screening for breast, cervix, and colorectal cancers (e.g., mammography, Pap testing, fecal occult blood testing, sigmoidoscopy, colonoscopy).

There is variation on which colorectal cancer screenings are viewed as required (i.e. fecal occult blood testing, sigmoidoscopy, or colonoscopy). For example, does a health center meet minimum HRSA Program Requirements if they only provide fecal occult blood testing or must they provide colonoscopies as well?

Also, there is variation on which breast cancer screenings are viewed as required (i.e. manual breast exams by palpation, mammograms, etc.). For example, does a health center meet minimum HRSA Program Requirements if they only provide manual breast exams by palpation or must they provide screening mammograms as well?

Clarification from HRSA is needed as to the minimum colon cancer and breast cancer screening services (manual breast exams by palpation, mammograms, etc.) required under Screening Services. However, our recommendation is to consider the UDS (Uniform Data System) operational definitions of both colorectal cancer and breast cancer screening metrics.

For example, the UDS breast cancer screening metric requires a screening mammogram. For the UDS colorectal cancer screening metric, Fecal occult blood test (FOBT), stool deoxyribonucleic acid (DNA) (sDNA) with fecal immunochemical test (FIT), flexible sigmoidoscopy, computerized tomography (CT) colonography, or colonoscopy, all meet the criteria.

In the absence of further guidance from HRSA, we recommend each health center should:

• Provide screening mammography either directly (Column I) or by formal written agreement (Column II or III).

• Provide fecal occult blood tests (FOBTs), stool deoxyribonucleic acid (DNA) tests (sDNAs) with fecal immunochemical tests (FITs), flexible sigmoidoscopies, computerized tomography (CT) colonographies, or colonoscopies, either directly (Column I) or by formal written agreement (Column II or III).

As your health center works toward HRSA Continuous Compliance, make sure you are reviewing the most recent HRSA/BPHC Site Visit Protocol and HRSA Compliance Manual long before your next FQHC Site Visit. Stay tuned to RegLantern’s blog for the most up-to-date guidance!

Reviewed: March 3, 2025