Guidelines for Designating School-Based Health Centers as Title X Sites

TO: Title X Delegate Agencies
FROM: CFHC Area Managers
DATE: August 30, 2006
RE: CFHC Guidelines for Designating School-Based Health Centers (Community College and High School Student Health Centers) as Title X Sites.

Based on reviews of common findings from site evaluations, as well as recent requests by several agencies to add new Title X sites, CFHC is providing the following requirement guidance for Delegate Agencies that currently have or would like to add School-based Sites (Community Colleges and/or High School Health Centers) as Title X sites. Below are details of the necessary administrative, clinical and fiscal requirements to make these sites Title X compliant.

Administrative

The site must either be a Family PACT provider with a Family PACT number or be providing Family PACT services as a satellite clinic under one of the agency’s other Family PACT numbers.

The site staff must follow all Title X administrative and legal policies and procedures as stated in the Title X Program Guidelines. There should be a copy of the Title X Guidelines at the clinic site and all staff working at the site should be familiar with these Guidelines.  Title X Guidelines may be downloaded from the CFHC Samples File.

All data must be submitted through the Semi-Annual Progress Report (SPR) to CFHC under a site number assigned by CFHC to the community college/high school site.

If the clinic staff at the school-based site is employed by the community college/school district and not by the delegate agency, the Delegate Agency must provide documented programmatic, clinical and financial oversight that ensures that the school-based site is in compliance with Title X Program Guidelines. In addition, the terms of the relationship, roles and responsibilities of the school-based site and delegate agency must be clearly stated in a subcontract that has been approved by the Community College Governing Board/School Board as well as the Delegate Agency Governing Board. This subcontract must also include all administrative, clinical and financial requirements included in the Title X Program Guidelines.

Clinical

The site staff must follow all Title X clinical policies and procedures as stated in the Title X Program Guidelines.

If the clinic staff at the school-based site is employed by the community college/school district and not by the Delegate Agency, the staff must follow the same Continuous Quality Improvement/Continuous Quality Assurance (CQI/CQA) policies and procedures as the Delegate Agency. Additionally, these policies and procedures must be included in the subcontract referenced above in the Administrative section.

Finance

Site staff must follow all Title X policies and procedures as stated in the Title X Program Guidelines, the Code of Federal Regulations (CFR), OMB Circulars A-133 (as applicable), A-110 and CFHC fiscal policies and procedures. Additionally, Title X required financial statements and reports from the school-based site must be submitted to CFHC in accordance with contract requirements.

If you have any questions regarding these requirements or would like technical assistance, please feel free to contact your Area Manager.