On December 18, 2024, the Health Resources and Services Administration (HRSA) issued new instructions to apply for initial designation as a “look-alike” health center. There are several significant changes, both in terms of the underlying requirements and the review process. For example, under the new application, HRSA will assess the independence of the applicant based on various criteria, such as whether most of the key management staff are directly employed by the applicant entity, and whether board members also work for an affiliated or related organizations. In addition, the updated application specifies that the narrative must address how the applicant provided the local community with notice of its intent to submit a look-alike application. The updated application also includes a greater emphasis on scrutinizing applications with proposed service areas that overlap with other health centers.

Are you considering whether look-alike health center designation may be a good fit for your organization? If so, then it is imperative that you understand these key changes to the look-alike application.

For questions on the look-alike application and strategies to overcome potential challenges, contact attorney Carrie Riley at criley@feldesman.com or 202.466.8960.