The Health Resources and Services Administration (HRSA) has published Program Assistance Letter (PAL) 2026-01, Calendar Year 2027 Requirements for Federal Tort Claims Act (FTCA) Coverage for Health Centers and Their Covered Individuals. 

PAL 2026-01 outlines the deeming requirements for health centers seeking FTCA coverage for Calendar Year (CY) 2027 and establishes a deadline of June 26, 2026, for submission of redeeming applications. HRSA cautions that eligible entities that fail to submit a timely redeeming application may experience a gap in FTCA coverage and should consider purchasing private malpractice liability insurance for CY 2027.

New Applicants

New applicants may submit an initial deeming application at any time the Electronic Handbook (EHB) is open. HRSA will notify active EHB users of system maintenance closures through EHB notifications and email.

Health centers seeking deeming for CY 2027 should submit applications sufficiently in advance to allow HRSA to complete its review before the start of the coverage year. Early submission is strongly encouraged (we recommend no later than October 1, 2026).

Application Updates

The deeming application for CY 2027 itself is nearly identical to last year’s (CY 2026) application. The following changes implemented in CY 2026 (from CY 2025) remain in effect:

• An award recipient’s deemed status does not apply to the subrecipient entity or their personnel
• Required FTCA trainings (Obstetrics, Infection Control, HIPAA, and Areas of Risk) are addressed through four separate questions (Review of Risk Management Systems, Questions 3(F)-3(I))
• Applicants must complete the “FTCA Educational Training Tracking Form”.
• Quarterly assessments must be uploaded into four sections (Review of Risk Management Systems, Questions 4(A) – 4(D))
• The credentialing and privileging section references PAL 2024-01 regarding temporary privileging during certain declared emergency situations; temporary privileges may be used only in those limited circumstances
• Credentialing and Privileging must be completed at least every two years.
• The claims management section continues to include an attestation regarding the  provisioning of documents for the Department of Health and Human Services, Office of the General Counsel, General Law Division (Claims Management – 2(c))

Review Process

HRSA is required by law to make a determination on the deeming application within 30 days after receipt. 

Applications will first be reviewed for completeness. If additional information or clarification is required, applicants will have 10 business days to respond. If HRSA determines that the health center has not demonstrated compliance and is at risk of being disapproved, HRSA will issue a “compliance notice” identifying deficiencies and providing 30 days to respond.    

For CY 2027, HRSA continues to limit the use of compliance notices. Health centers that receive an FTCA Site Visit as part of the application review may, under certain circumstances, not receive a “Compliance Notice” prior to disapproval.

If you have any questions regarding the FTCA deeming application process or need assistance with the deeming application please contact either Martin J. Bree or Andrea C. Harris.

Learn more about what’s new in FTCA coverage, liabilities, and risk areas in our upcoming trainings:

Nuts and Bolts of the CY2027 FTCA Deeming Application
April 13, 2026 at 1 p.m. ET
https://training.feldesman.com/community-health-centers/content/nuts-and-bolts-cy2027-ftca-deeming-application

FTCA Risk Management and Compliance Summit
May 12-13, 2026
https://training.feldesman.com/community-health-centers/content/ftca-risk-and-compliance-summit-0