Factors to Consider when Completing a Change in Scope

Before submitting a Change In Scope (“CIS”), health centers must understand adjusting their scope of services goes beyond just completing Forms 5A, B, and C. A Scope of Project defines a health center’s approved service sites, services, providers, service area and target population. The scope of project must be consistent with federal status and must also consider a health center’s mission and vision. When considering completing a CIS, health centers should analyze the following:

  1. Service Sites: Will changing the scope of project mean adding a new service site, deleting a site, or merging two sites into one? It’s important for health centers to review Policy Information Notice (PIN) 2008-01 as this is one of the few PINs that are still applicable to health centers. This PIN outlines the definition of a service site, types of sites that can be added to scope, and other factors to consider.
  2. Target Population: While health centers serve all regardless of ability to pay, health centers must serve a medically underserved area/population and, if applicable, HRSA designated special populations. Utilizing a needs assessment that is current and reflective of the community served will help to determine how the target population will be affected by completing a CIS. Health Centers must ensure that any changes to scope do not result in a barrier to care for patients served.
  3. Service Area: A health center’s service area is the area where the majority of health center patients reside. HRSA requires that 75% of current health center patients reside in a health center’s service area. It is important to review zip codes and any other data to determine where patients come from, if the service area is changing, and other resources within that particular area. The UDS mapper is one resource that can be used to evaluate characteristics of your community, and a UDS map is required by HRSA when completing a CIS. 
  4. Services and Providers: Health Centers are required to provide certain services which are documented in Form 5A. Services provided are defined for the entire organization and not by site. The mode of delivery is up to the health center; are services provided by practitioners that are employed, volunteers, contracted or through written formal arrangements? Although the health center decides the mode of delivery of required services, these must be board approved. Understanding the characteristics and composition of the community you serve will help provide guidance when making this decision. For example, would adding a pediatrician duplicate services provided within the community if the pediatricians in your community accept the health center’s patients? 


As health centers go through the process of completing a CIS, the following items should be adhered to:

  • Most recent and readily available data is used to determine the direction of how a health center should proceed
  • Involve patients through patient surveys, focus groups or patient board members when evaluating which services or sites could be added or improved
  • If there are any questions, utilize the assigned HRSA Point of Contact 
  • Document discussions of CIS within board meetings as any CIS must be board approved

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