On August 11, 2026, the Health Resources and Services Administration (HRSA) released its long-awaited Scope of Project Policy Manual, replacing the separate scope of project policies previously set forth in Policy Information Notices or PINs. HRSA also released its responses to the comments on the draft Scope Manual, which provide additional insight into HRSA’s rationale for certain new policies and criteria.

The new Scope Manual consolidates and updates HRSA’s scope of project guidance and is intended to:

• Update scope criteria to reflect requirements in the current Health Center Program Compliance Manual and applicable grant regulations;
• Clarify certain general scope of project principles, including Change in Scope processes and forms with the goal of streamlining decision-making and reducing administrative burden;
• Establish specific criteria for new sites that are co-located with other organizations and/or operated by contractors or subrecipients; and
• Incorporate more recent policies, including those addressing telehealth and temporary service sites, into HRSA’s overall scope of project guidance.

New Scope Manual Takes Effect Immediately

The Scope Manual is effective immediately for all new change in scope requests and other changes to, and reviews of, a health center’s scope of project. Health centers planning to submit a Change in Scope request should review the new Manual as soon as possible to determine how the revised policies and criteria may affect their request.

Although the Scope Manual is already in effect, HRSA has indicated that it intends to work with health centers to update existing scopes of projects starting in 2027. This process is expected to follow anticipated revisions to HRSA’s online Change in Scope request system in November 2026, which will incorporate the new Scope Manual and is intended to streamline the Change in Scope process.

Impact on Upcoming Operational Site Visits

For health centers with upcoming Operational Site Visits (OSVs), HRSA has indicated that reviewers will continue to use the current Site Visit Protocol until it is updated to reflect the new Scope Manual, which HRSA anticipates will occur around February 2027. 

Nevertheless, all health centers, including those preparing for OSVs, should familiarize themselves with the new Scope Manual. The Manual may provide important guidance for evaluating scope of project considerations incorporated into the Health Center Program Compliance Manual, which remains the primary policy guidance used during OSVs.  

Additional Guidance and Upcoming Webinar    

Feldesman attorneys are reviewing the new Scope Manual and HRSA’s responses to public comments. In the coming days, we will provide additional guidance for federally qualified health centers (FQHCs), look-alikes, and subrecipients of Section 330 funding regarding significant changes to existing scope of project policies and the practical implications for health center operations. 

Upcoming Feldesman Webinar

Join us on August 26, 2026, at 1 p.m. ET, for an industry update webinar examining the major scope of project changes and how they may impact your health center’s current and future operations. 

If your health center has questions regarding the new Manual, please contact Marcie H. Zakheim or any member of our Health Center team.