As outlined by “Chapter 7 – Coverage for Medical Emergencies During and After Hours” of the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual, Federally Qualified Health Centers (FQHCs) are required to ensure access to care during normal business hours, as well as after-hours, including for medical emergencies.  This includes having systems in place that ensure the following:

• Coverage is provided via telephone or face-to-face by an individual with the qualification and training necessary to exercise professional judgment in assessing a health center patient’s need for emergency medical care; and
• Coverage includes the ability to refer patients either to a Licensed Independent Practitioner (LIP) for further consultation, or to locations such as emergency rooms or urgent care facilities for further assessment or immediate care as needed. 

Many health centers meet this requirement by choosing to contract with a nurse triage service, to help patients access care in a timely and appropriate manner.   

While each contract contains its own unique provisions, nurse triage calls handled by a contracted service typically do not result in a qualifying visit and therefore are not eligible for reimbursement. For billing to occur, the interaction must meet the criteria for an FQHC visit and be delivered by a qualified provider, as well as documented as a face-to-face or approved telehealth encounter.