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 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. For now, the most conservative recommendations would be to:

• Provide (or have a contracted or referral arrangement for) screening mammography and indicate it under Column I (if manual breast exams or mammograms are completed by your health center staff) and Column II or III (if mammograms are provided through a contract or referral arrangement) for Screening Services.

• Provide (or have a contracted or referral arrangement for) colonoscopies and indicate it under Column I (if fecal occult blood testing or colonoscopies are completed by your health center staff) and Column II or III (if colonoscopies are provided through a contract or referral arrangement) for Screening Services.
  

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!