Providing seamless access to care is a fundamental requirement for Federally Qualified Health Centers (FQHCs). “Chapter 7 – Coverage for Medical Emergencies during and After-Hours”, of the Health Resources and Services Administration (HRSA) Health Center Compliance Manual (Compliance Manual Chapter 7), requires the health center have clearly defined arrangements in place for promptly responding to patient medical emergencies after the health center’s normal business hours.  

To evaluate compliance with the HRSA Health Center Program Requirements, the clinical reviewer is required to place a test call to the after-hours line during an Operational Site Visit (OSV) to evaluate the system in real time. Guidance provided by HRSA indicates site visit teams are prompted to call the health center, once the health center is closed, via this instruction, “Using contact information for after-hours coverage (for example, phone number provided by front desk staff, on signage, in brochures, or on health center’s website), call the health center once the health center is closed.” 

The test call assesses the functionality and reliability of the after-hours process and verifies the following:

• After-hours coverage is provided via telephone or face to face by an individual with the qualification and training necessary to exercise professional judgment in a assessing a patient’s need for emergency medical care; 
• After-hours coverage includes the option to refer patients either to a Licensed Independent Practitioner (LIP) for consultation or to locations including urgent care or hospital emergency rooms;
• After-hours coverage addresses notification and ensures access to the Limited English Proficiency (LEP) patient population.  

A test call to the after-hours line during an OSV is a crucial way to validate that FQHCs offer patients continuous access to care. While it is clear the call will take place, recent guidance provided by HRSA demonstrates site visit teams have discretion on when the after-hours call will take place; therefore, the call may be placed during the OSV or even a week before. HRSA does not specify exactly when the call will be made during the OSV; therefore, health centers are expected to maintain continuous compliance.