Health Resources and Services Administration has issued HRSA Notice of Award updates that are now appearing in Health Center Program awards. These HRSA NOA updates include new conditions and clarifications related to compliance, grant terms, and enforcement.
HRSA also issued a Letter to Grantees emphasizing compliance with applicable laws.
Below are the key HRSA NOA changes health centers should be aware of.
New Items Included in Updated Notices of Award
Parental Consent Requirements for Services Provided to Minors
Before any minor receives medical, dental, behavioral health, or other service at a HRSA-supported health center, the health center must obtain consent from the parent or legal guardian in accordance with any applicable state or federal laws. This applies to all types of care, including treatment, preventive services, and counseling. It also includes services related to sensitive topics such as sexual identity or reproductive health. State, federal, and local laws that govern parental consent and notification already apply, and health centers must follow them at all times as a condition of receiving Health Center Program funds.
Federal Antidiscrimination Compliance as a Condition of Funding
By applying for or accepting federal funds from HHS, recipients certify compliance with all federal antidiscrimination laws and these requirements and that complying with those laws is a material condition of receiving federal funding streams. Recipients are responsible for ensuring subrecipients, contractors, and partners also comply.
Applicability of NOA Terms Subject to Court Orders
Any term or condition in this NOA, including those incorporated by reference, that HHS is enjoined by court order from imposing or enforcing shall not apply or be enforced as to any recipient or subrecipient to which that court order applies and while that court order is in effect.
HRSA Letter to Grantees
In a separate HRSA Letter to Grantees, the agency reminded Health Center Program recipients of their responsibility to comply with applicable local, state, and federal laws. The letter notes that these laws may include parental consent requirements for minors receiving health care. It also emphasizes that noncompliance with grant terms and conditions will not be tolerated.
Health centers should review their current Notices of Award and recent HRSA communications to ensure awareness of these HRSA grant compliance updates.
Burrows Consulting supports health centers in reviewing HRSA Notice of Award language and understanding operational and compliance considerations related to these updates.
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