Earlier this year, the American College Health Association (ACHA) explored methods by which college campuses could address challenges in training, recruiting, and maintaining properly trained well-being staff. One of the proposed solutions for meeting the health demands of college populations was college participation within the National Health Service Corps (NHSC) site designation program.
As previously reported, the NHSC site designation program allows eligible outpatient and medical provider sites in underserved communities to receive a designation to help address community well-being needs through various employee recruitment and retention incentives/tools. It also allows those sites that are so designated to use a federally authorized Sliding Fee Scale Discount Program (SFSDP).
Such a designation can help colleges meet staffing needs, and the use of the sliding fee scale reduces potential college legal concerns around using tuition/fee funds (or any other source of income as a form of Student Administrative Health Fee) to pay for remaining balances not covered by insurance, and (1) not have any conflict with the payer of last resort provisions in Medicaid, TRICARE, other governmental insurance; and (2) not require approval of insurance payers for the SFSDP.
During the summer of 2024, ACHA continued our conversations with the U.S. Health Resources and Services Administration (HRSA), which is responsible for overseeing the NHSC site designation program. These meetings served the purpose of communicating ACHA members’ experiences in applying for the program and exploring additional methods by which colleges could be considered for this program.
The HRSA reiterated that college applications are evaluated on a merit basis and that sites that meet statutory eligibility criteria would still be able to qualify for the program. The statutory eligibility criteria that colleges must consider when applying include:
- location within a geographical health professional shortage area (HPSA)
- acceptance of Medicare and Medicaid, and
- confirmation of the presence of a sliding fee scale for the provision of services that ensures access to care for patients whose income is below the poverty level.
Therefore, if your college health center site can potentially meet the applicable statutory criteria requirements, HRSA encourages the submission of an application to receive designation. After communicating ongoing challenges experienced by college sites that applied, the HRSA said that they will stress with their regional staff to bring up questions when non-traditional sites (e.g., college health centers) apply for the program.
The meeting also allowed the HRSA to communicate some of the challenges that the NHSC site designation program experiences. As the program is subject to the Congressional Appropriations process, funding levels provided to designated sites are distributed on a high-need basis. Therefore, the HRSA cannot guarantee that sites that receive the designation end up receiving recruitment and loan-repayment benefits after they obtain the NHSC designation.
Our conversations with the HRSA have helped educate the agency about how college health centers tend to work and helped ACHA make the case that college health centers play an important role in community health, but the hurdles for colleges to obtain the designation are still substantial. And even if the designation is awarded, there is still a real possibility that the employee recruitment and retention provisions will not be available due to federal funding restraints. Colleges should keep that in mind when considering whether to apply for the NHSC designation during next year’s application period.
ACHA has begun discussions with Congress on how the NHSC program could be statutorily improved to make it easier for colleges to qualify for designation. These efforts are still in the beginning stages and as they progress, we look forward to keeping you informed.
Meanwhile, you should continue to evaluate, based on the qualification criteria above, whether it is appropriate for your college health center to apply for designation. The next application period will likely be in May/June of 2025. Those considering applying should review HRSA’s NHSC Site Reference Guide and the NHSC Site Agreement to help in the evaluation process. HRSA will also answer any questions relating to the application process or program either via telephone at 800-221-9393 or online via their Customer Service Portal. And please continue to share your experience with ACHA to help inform our reform efforts.
Additionally, the HRSA recommends that college health centers look into the Substance Use Disorder Treatment and Recovery (STAR) Loan Repayment Program as another potential option for colleges to address staffing and retention issues.
If you have other policy-related questions, concerns, and suggestions to advocacy@acha.org.
Topic
Advocacy & Legislation
Post Type
Advocacy Updates
