Last updated: November 2026
Health center application readiness is the work an organization does before it applies to become a federally funded health center through a New Access Point (NAP) grant, or a Health Center Program look-alike through designation, under section 330 of the Public Health Service Act. Integral Healthcare Solutions (IHS) drafts the governance, needs-assessment and policy documents for those applications and tests them against the Health Center Program Compliance Manual and the 42 CFR Part 51c grant regulation. Counsel and the board approve every document, and the applicant submits to HRSA.
IHS was founded in 2002 by Thomas G. Goddard, JD, PhD, former URAC COO and General Counsel. IHS is a consulting firm with three practice lines: accreditation consulting, compliance services and program development.
What are a New Access Point application and a look-alike application?
A New Access Point application asks the Health Resources and Services Administration (HRSA) for grant funding to open new health center service sites. A look-alike application asks HRSA to designate an organization that meets all Health Center Program requirements without program funding. HRSA's New Access Points notice of funding opportunity (NOFO) HRSA-25-085 says NAP is the main way organizations become funded health centers (HRSA-25-085 NOFO, issued May 30, 2024; PDF opened November 5, 2026). HRSA's look-alike page confirms that designation carries no program funding (page opened November 5, 2026).
The governing documents, in the order an applicant meets them:
- Regulation. 42 CFR Part 51c, Grants for Community Health Services (eCFR current text; title 42 last amended October 8, 2026; opened November 5, 2026).
- Compliance Manual. HRSA's Health Center Program Compliance Manual has 21 chapters and shows its text as last updated August 2018 with a technical revision dated November 20, 2025 (page opened November 5, 2026).
- Application documents. The NOFO for a NAP application; the look-alike initial designation instructions and forms in the HRSA Electronic Handbooks (EHBs) for a look-alike.
HRSA's New Access Points page (last reviewed August 2026; opened November 5, 2026) covers managing fiscal year 2026 NAP awards and links HRSA-25-085. HRSA's look-alike initial designation page says an organization may apply at any time.
Who needs readiness work, and what triggers it?
On August 13, 2026, HHS announced 102 million dollars in NAP awards to 158 new and existing health centers for 415 new sites (HHS press release, opened November 5, 2026). Triggers:
- A nonprofit or clinic wants NAP funding and has no board, bylaws or needs assessment built to Program rules.
- A clinic already delivers primary care in its area and wants look-alike designation, which requires showing that no other entity owns, controls or operates it.
- A look-alike is weighing a NAP application, which the NOFO says would end its look-alike status if awarded.
- HRSA releases a NAP NOFO. The one we read was issued May 30, 2024 with a first due date of August 30, 2024.
Whether to apply, and by which route, is a decision for the organization and its board.
How IHS helps
IHS tests the organization against the requirements an applicant must show, drafts what is missing and leaves a clear list of what remains. The steps:
- Gap assessment. IHS compares governance, needs assessment, services, sites, policies and financial systems with the Compliance Manual and with the NOFO or look-alike instructions in force when you apply.
- Eligibility file. IHS lists the documents that prove nonprofit or public agency status and, for a look-alike, the evidence of independence from other entities.
- Board work. IHS compares the board roster and bylaws with the composition and selection rules and drafts bylaws language for counsel and the board to approve.
- Needs-assessment structure. IHS lays out the service area, data sources and narrative to cover what the Compliance Manual lists. The organization supplies the data.
- Policy drafting. IHS drafts program and clinical content for the client’s clinicians, leadership and counsel to approve, including sliding fee, quality, financial management and billing policies.
- Evidence mapping and mock review. IHS maps documents to application requirements, conducts a mock review and supports readiness by identifying unresolved gaps.
The applicant supplies service area data and patient demographics, its board roster and bylaws, financial statements and audit reports, clinical policies, staffing and site information, and the current HRSA instructions. The real limit: IHS does not submit to HRSA or contact HRSA, does not predict an award or designation decision and gives no legal advice. Counsel reviews the bylaws.
What to have ready
Checklist sources: the Health Center Program Compliance Manual (August 2018; technical revision November 20, 2025), current eCFR, and historical NOFO HRSA-25-085 (issued May 30, 2024; modified July 26, 2024). All were opened November 5, 2026.
- Nonprofit or public agency eligibility documents appropriate to the entity; an IRS tax exemption certificate is one nonprofit option (Compliance Manual, chapter 1).
- For a look-alike: evidence of current primary care delivery in the proposed service area, independence from another entity and absence of a current Health Center Program federal award (chapter 1).
- Form 5B service-area ZIP codes based on current or proposed patients’ residences, reviewed annually, and a needs assessment using the latest service-area and applicable special-population data (chapter 3).
- A board roster and bylaws checked for patient eligibility, composition, selection and removal, including applicable waivers and exemptions (chapter 20).
- For centers supported under subpart C, cost-based fees and discounts adjusted to ability to pay: full discounts at or below the poverty guidelines, no discounts above twice those guidelines, and nominal fees at or below the guideline levels only when consistent with project goals (42 CFR 51c.303(f)).
- For centers supported under subpart C, ongoing quality assurance with assigned responsibility and periodic assessments by physicians or licensed professionals under physician supervision, using systematic patient-record review and documenting and implementing indicated changes (42 CFR 51c.303(c)).
- A Form 5A services plan: under HRSA-25-085, mental health and substance use disorder services could be direct, contracted or through formal referral; general primary medical care had to be direct or through paid contracts.
- A Form 5B site list: HRSA-25-085 required new start and look-alike applicants to propose a fixed site with primary medical care as its main purpose, open at least 40 hours weekly; it had to operate year-round unless applying only for Migrant Health Center funding.
- For a NAP application, collaboration evidence and consistent budget forms (HRSA-25-085).
If several items are missing, bring the list to the free introductory call and IHS will scope the work around your timeline.
How it compares
The NAP column summarizes the closed HRSA-25-085 competition, not a current funding offer. Chapter 1 bars new dual status as both a section 330 award recipient and a look-alike and requires a look-alike seeking program funding to propose all its sites within the award’s scope. It preserves pre-existing dual status as of the manual’s release if HRSA approves subsequent Service Area Competition and Renewal of Designation applications. The organization and its counsel choose the route.
| Question | New Access Point (HRSA-25-085) | Look-alike initial designation |
|---|---|---|
| What HRSA provides | Historical ceiling: 650,000 dollars per award, including direct and indirect costs, subject to appropriations; the notice listed June 1, 2025–May 31, 2026 | Designation without program funding, with the benefits HRSA lists |
| When to apply | When HRSA issues a NOFO, in two phases: Grants.gov, then EHBs (August 30 and September 30, 2024 for this notice) | At any time, with 90 days to complete the application in EHBs |
| After approval | All proposed sites and Program compliance were due within 120 days of the notice of award; failure to verify a site’s opening triggered a condition allowing up to 120 more days for that site. New start/look-alike OSVs were planned about 120 days after award, with possible delay until sites opened | Report progress every year and renew designation every four years |
What it costs
The HRSA pages reviewed do not list an application fee; that does not establish that applying has no costs. The historical HRSA-25-085 notice required no cost sharing or matching. Verify current fees and terms with HRSA.
IHS scopes each engagement after a free introductory call.
What this is not
- It is not legal advice. IHS is a consulting firm, and counsel reviews bylaws and policies.
- It is not a prediction or guarantee of an award or designation. IHS does not submit anything to HRSA or contact HRSA for the applicant.
- It does not replace HRSA’s current instructions or cover existing-center Operational Site Visit preparation; see the related FQHC site visit page.
Frequently asked questions
What is a Health Center Program look-alike?
A look-alike is an organization that HRSA designates as meeting all Health Center Program requirements without receiving program funding. HRSA's page lists Medicare and Medicaid payment under the FQHC prospective payment system, 340B drug pricing, Vaccines for Children, National Health Service Corps support and technical assistance as benefits, and says the Federal Tort Claims Act does not offer malpractice insurance for look-alikes.
What is a New Access Point application?
A New Access Point (NAP) application asks HRSA for grant funding to open new health center service sites. The NAP notice we read, HRSA-25-085, says NAP is the main way organizations become funded health centers. It allows three kinds of applicant: a new start, a look-alike and a satellite (an existing funded health center).
How do a New Access Point and a look-alike differ?
Under the closed HRSA-25-085 competition, applicants could seek up to 650,000 dollars, including direct and indirect costs, subject to appropriations. A look-alike application seeks designation without program funding and can be filed at any time.
What governing board does HRSA require?
Chapter 20 generally requires 9–25 voting members and a patient majority of at least 51 percent; board-size waivers require good cause and demonstrated inability to meet the requirement. Patient eligibility, representation, member selection and employee-family exclusions follow the chapter’s detailed criteria; generally no more than half of non-patient members may earn over 10 percent of annual income from health care, but the limit is two-thirds for section 330(g)-only awardees/designees. A center with section 330(g), (h) and/or (i) support and no section 330(e) support may request a patient-majority waiver for good cause, subject to HRSA approval. The chapter’s board-composition exemption covers the specified tribal and urban Indian organizations; for a public agency with a co-applicant, the requirements apply to the co-applicant board.
What must a needs assessment cover?
The Compliance Manual calls for a needs assessment at least every three years using the latest available data for the current or proposed service-area population and, where applicable, special populations. It covers access to and use of care, major causes of illness and death and related disparities, and other characteristics affecting health status, access or use of primary care.
When can an organization apply?
A look-alike application can be filed at any time, and HRSA gives 90 days to complete it in the Electronic Handbooks. NAP applications open when HRSA issues a notice of funding opportunity; the NAP page we opened on November 5, 2026 covered managing fiscal year 2026 awards, with no open application.
What does HRSA score in a NAP application?
HRSA-25-085 listed seven review criteria: need (10 points, plus an unmet need score worth 20), response (25), collaboration (10), impact (5), resources and capabilities (15), governance (10) and support requested (5). Look-alike applicants could also earn up to 10 priority points under conditions the notice lists.
What does IHS draft, and what does the applicant submit?
IHS drafts the gap assessment, eligibility file, bylaws language, needs-assessment structure and policies for counsel and the board to approve. The applicant submits the application and deals with HRSA. IHS does not submit anything to HRSA or contact HRSA.