HRSA Form 5A Service Descriptors Document Updates

Services are one of five elements that comprise the scope of project, as described in the HRSA Health Center Program Scope of Project Policy Manual (“Scope Policy Manual”). Our last post provided a summary of the manual that you can read in greater detail. While studying the Scope Policy Manual, we noted that some language that typically was used in the HRSA Service Descriptors for Form 5A: Services Provided document was slightly different in the Scope Policy Manual.

That led our team to review the Service Descriptors documents to see if anything had been updated there. We initially saw that the “last updated” date on the document was unchanged (April 2026 at the time of writing this post). But upon further review, our team noted there were some significant changes that had occurred since we last reviewed the document carefully after the April 2026 updates.

This blog post highlights the changes that are important for health center leaders to know. Given these changes, it is wise for every health center to immediately review its HRSA Form 5A to ensure it is current and compliant.

Let’s take a look at some of the key changes.

General

The initial guidance has been updated to reflect some of the key language emphasized in the Scope Policy Manual. It’s also important to note that there are a number of inconsistencies that do not seem to be completely aligned with and updated to the language in the Scope Policy Manual as well. But the key areas that the Service Descriptors document highlights in its initial “Background” section indicating that:

• Services provided by a health center are defined at the grantee/designee level, not by individual site. Thus, not all services must be available at every health center service site; rather, health center patients must have reasonable access to the full complement of services offered by the center as a whole, either directly or through formal written established arrangements.

• Once a service is included in the approved scope of project, it must be available to all patients regardless of ability to pay and be discounted in accordance with the health center’s sliding fee discount program.

• Health centers should ensure services are provided in a linguistically appropriate manner based on the target population(s). In assuring that services are appropriate for the needs of the patient population served, the health center must take reasonable steps to provide meaningful access to health center services for patients with limited English proficiency.

• The descriptors for the Required Services provide a “floor” for what elements, at a minimum, are included for a particular service.

• Where applicable, the descriptors provide detail as to what “may” (but is not required to) be included for a particular service to account for health centers that may provide a more expansive or an intense level of a service. In these instances, a separate change in scope (CIS) request is not needed.

• The descriptors also identify a “ceiling” that clarifies what is not included in a particular service and thus where a separate change in scope request is required.

• When considering what additional services to provide, health centers should thoroughly investigate the costs, benefits, and risks before making such decisions. In general, a health center must prioritize making required primary health services available to all patients before proposing to add additional health services, including additional specialty services. Each health center must determine whether adding additional services as part of the approved scope of project is appropriate for the population served, demonstrated unmet need, and other relevant factors.

• When a proposed specialty service change in scope request is approved, only those aspects of the specialty service, described within the change in scope request, will be included within the approved scope of project.

Screenings

The current service descriptor for “Screenings” simply aligned the “special populations” language with the Scope Policy Manual’s language for “special medically underserved populations”. There were no other significant changes for this Form 5A service.

Obstetrical Care

The service descriptor names falling under the Obstetrical Care service (prenatal, intrapartum, and postpartum care) are now just divided differently and formatted slightly different, but there were no other significant changes for this Form 5A service.

Preventive Dental

The service descriptor for preventive dental services had the most significant changes. Previously, the descriptor contained detailed language of all the categories of services included in the “parent” service of preventive dental. These included stating the minimum required services as, “basic dental screenings and recommendations for preventive intervention, oral hygiene instruction and related oral health education (e.g., prevention of oral trauma and oral cancer), oral prophylaxis, and topical application of fluorides/prescription of fluorides for systemic use when not available in the water supply”.

With the recent update, the service descriptor is simplified to two short sentences:

“Preventive dental services prevent diseases of the oral cavity and related structures. Services may include application of sealants and diagnostic screening for caries and periodontal disease through the use of dental X-rays.”

HP Required Substance Use Disorder Services (Homeless Population only)

This service was renamed from what was previously called “HCH Required Substance Abuse Services” to “HP Required Substance Use Disorder Services (Homeless Population only)”.

The definition itself changed slightly to read:

“Substance use disorder services are screening, diagnosis, and treatment services for substance use disorders (e.g., abuse of alcohol, tobacco, prescription drugs). At a minimum, these services include age-appropriate risk reduction and counseling to address identified risk factors and support abstinence; detoxification to manage withdrawal symptoms associated with substance use disorder; and treatment/rehabilitation, to include individual and/or group treatment, counseling, and case management. Treatment may occur in outpatient or short-term residential settings and may include medication-assisted treatment (e.g., buprenorphine products, methadone, naltrexone).”

The key changes involve the insertion of “age-appropriate” language and the modification and removal of “risk/harm reduction” language. We interpret these changes to be aligned with some of the initiatives of the current administration.

Outreach

The service description for outreach services changed only slightly, removing language that stated services must be “culturally and linguistically appropriate”. As above, we read these changes as consistent with the current administration’s priorities.

Translation

The service description for translation services changed only slightly, removing language that stated services must be “culturally responsive”. We read these changes as consistent with the current administration’s priorities.

Behavioral Health Services

As with Obstetrical Care above, the Behavioral Health Service names and descriptors are reorganized and reformatted, with no other significant changes for this service.

The one paragraph that did change slightly falls under Substance Use Disorder Services:

“These services may include: age-appropriate risk reduction and counseling to address identified risk factors and support abstinence; detoxification to manage withdrawal symptoms associated with substance use disorder; and/or treatment/rehabilitation, to include individual and/or group treatment, counseling and case management.”

The changed language seems to surround the idea of harm/risk-reduction language, as well as age-appropriate counseling services. The remainder of the definitions remain intact. These changes appear to be largely semantic in nature and not significantly substantive.

Nutrition

This service descriptor changed significantly. The definition now reads:

“Nutrition services can help to prevent, manage, and treat diseases and conditions through nutritional and food-based interventions. These services may include:

• Nutritional assessment and treatment, including counseling and patient education.

• Medical Nutrition Therapy.

• Nutrition instruction (for example, promote healthy eating and meal preparation and improve food literacy).

• Weight management programs (for example, group visits).

• Nutritional and food-based interventions to help prevent, manage, and treat diet-related chronic diseases and promote health.

• NOTE: Nutrition services are separate and distinct from:

  • Basic nutrition recommendations or dietary education provided during general primary care visits.

  • Helping patients apply for or enroll in food assistance programs such as Supplemental Nutrition Assistance Programs (SNAP), Women, Infants, and Children (WIC), or other federal, state, and local nutrition and food assistance programs that would be recorded under the Eligibility Assistance service.”

The key differences appear to be around the WIC program now being recorded under the Eligibility Assistance service on Form 5A (whereas it was clarified in the old description to fall under Nutrition if it was an in-scope service). The other key changes to this definition appear to be the insertion of “food-based” and “diet-related chronic disease” language, as well as adding “weight management programs” to this descriptor. These appear to be aligned with the “Make America Healthy Again” movement, focusing on food-based interventions and weight management activities.

Additional Patient Support Services

Previously called “Additional Enabling/Supportive Services”, this definition changed only slightly to now read:

“Additional patient support services are beyond any required services and support a health center patient’s access to health center services or non-medical, social, educational or other related services (e.g., child care, food banks, employment and education counseling, legal services/legal aid).”

The changes in this section largely appear to be more grammatical changes with little significance. However, a new note was added that clarifies that, “These services are separate and distinct from Case Management, Eligibility Assistance, Outreach, Transportation, Translation, and Health Education.”

Specialty Services

Finally, all definitions for “Specialty Services” were completely deleted from this document. This is aligned with the Scope Policy Manual moving all specialty services under the category of “Additional Services”. It appears that there will no longer be any definitions for these “Specialty Services” at all.

Next Steps For Health Centers

With all these changes, it would be a good time to set up a Form 5A review with RegLantern’s HRSA compliance team. Contact us today to get a review scheduled and ensure you are fully compliant!

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).