BPHC Update on Psychiatry Scope
Recently there have been some requests for clarification regarding the Bureau of Primary Health Care (BPHC) policy requiring psychiatry to be specifically added to a Health Center’s scope. Several Michigan Health Centers have recently applied for a change of scope to address this. Below is a response from the BPHC Office of Policy and Program Development:
"In order to provide the Health Center with the greatest assurances that, in the case that there are any challenges to their program (e.g., FTCA claim, reimbursement questions, 340B eligibility questions), psychiatry will be considered part of their scope of project, it should be reflected on their Form 5A as an Additional Specialty Service. This can be accomplished by submitting a CIS request to add psychiatry as a specialty service. In this request, they can specify that these services will include any applicable sub-specialties, as well. While we understand that the Health Center may already have a psychiatrist listed on Form 2 (Staffing Profile) and/or in the UDS Staffing Table, the Specialty Services PIN concerns adding the service, not the provider. It is conceivable, for example, that there may be a psychiatrist on staff who only provides a more limited range of services that might also be provided by a LCSW, rather than "psychiatry services.” However, if the health center is actually providing psychiatry services, "Psychiatry” is in fact specifically identified in the Specialty Services PIN as a specialty service (Part VI.A). Therefore, inclusion within the health center’s scope of services of "Behavioral Health” under Form 5A –Additional Services is not sufficient to cover psychiatry as a specialty service. To add psychiatry services to scope, the grantee should submit a CIS to Add a New Service that complies with both the requirements of the Scope PIN 2008-01 as well as the Specialty Services PIN 2009-02. There is a good summary at Attachment A of the Specialty Services PIN here: http://www.bphc.hrsa.gov/policiesregulations/policies/pin200902purpose.html, but the grantee should still review the appropriate parts of the full PINs as well. As a reminder in genera l -in order to provide the Health Center with the greatest assurances that, in case that there are any challenges to their program, sites, services and/or other activities will be considered part of their approved scope of project, Health Centers should periodically review their overall scope of project (Form 5A, 5B and 5C) in EHB to assure its accuracy and request any appropriate change in scope actions to update as necessary."
Please let Becky Cienki know if you have any additional questions or concerns.