Form 5A alignment
Updated user-facing terminology and service-delivery classifications aligned with HRSA’s current Form 5A framework, while preserving historical internal data keys.
DirectContracts & SubawardsCooperative Arrangements
HRSA policy update · August 2026
HRSA changed Scope of Project. RIEL is ready for what comes next.
PAL 2026-04 and the new Health Center Program Scope of Project Policy Manual reshape how health centers document services, sites, Change in Scope workflows and post-approval verification. RIEL is aligning its Scope of Project workflows ahead of HRSA’s November 20, 2026 EHB transition.
- Built for FQHC operations
- Human-reviewed decisions
- Policy-aware workflows
Scope of Project — 2026 alignment status
Form 5ADelivery methods
Updated model
Form 5BSites & settings
New structure
CIS workflowRequest pathways
Rule-aware
Deadline intelligence60 · 60 · 120 days
Tracked
RIEL’s implementation preserves historical data while updating the user-facing regulatory model and workflow logic.
November 20, 2026: HRSA says the EHB scope module improvements take effect and existing Form 5A and Form 5B scope data will be administratively migrated to the updated formats.
Read PAL 2026-04 ↗WHAT CHANGED
A familiar workflow is getting a new regulatory structure.
HRSA is updating the language and structure used to document Scope of Project in EHBs. The change is more than a cosmetic rename: it affects service delivery terminology, site classifications, checklist pathways and the way health centers track CIS activity.
| Current / legacy terminology | becomes | HRSA 2026 terminology | Operational impact |
|---|---|---|---|
| Form 5A Col. I · Direct (Health Center Pays) | Direct | Visible terminology and service-delivery classification | |
| Form 5A Col. II · Formal Written Contract/Agreement | Contracts and Subawards | Contract readiness and scope documentation | |
| Form 5A Col. III · Formal Written Referral Arrangement | Cooperative Arrangements | Agreement classification and discrepancy logic | |
| Form 5B: Service Sites | Form 5B: Sites expanded types | Service Site, Other Site and TCCS site structure | |
| One generalized change path | Formal · Scope Adjustment · Self-Update | Classification of the correct EHB workflow |
RIEL RESPONSE
HRSA changed the framework. RIEL operationalizes it.
RIEL turns the policy change into concrete workflow behavior so the team sees the terminology, deadlines, classifications and supporting evidence in the same place where the work is managed.
CIS decision support
Workflow logic can distinguish among Formal CIS, Scope Adjustment and Self-Update pathways instead of treating every change as the same kind of request.
FormalScope AdjustmentSelf-Update
Deadline intelligence
Separate clocks for HRSA review, Change Request response and post-approval scope verification help teams see what deadline actually applies and what happens next.
60-day review60-day response120-day verification
Form 5B: Sites
RIEL’s site model can reflect Service Sites, Other Sites and Transitional Care in Carceral Setting sites, together with the updated setting and location-type structure.
Service SiteOther SiteTCCS
Contract & subaward readiness
Agreement reviews can be mapped to the current Scope Manual requirements, helping teams identify missing contractual elements before those gaps turn into submission friction.
Required elementsEvidenceSite linkage
Policy-aware guidance
User-facing references and workflow logic are tied to the current Scope Manual and PAL framework rather than leaving superseded citations embedded in operational screens.
Current guidanceEffective datesTraceable source
THREE CLOCKS, THREE DIFFERENT OBLIGATIONS
The deadline is not one number.
PAL 2026-04 consolidates the CIS process and timelines. RIEL treats these as distinct operational events rather than collapsing them into one generic “processing days” field.
60days
Standard HRSA review
The standard timeline for HRSA review of a complete CIS request. HRSA may extend review when additional analysis or information is needed.
60days
Change Request response
When HRSA issues a Change Request, the health center has up to 60 days to respond. The standard review period restarts when the response is received.
120days
Scope verification
Following initial approval, the health center responds to the scope verification task confirming implementation before HRSA documents the change in approved scope.
Why this matters: a CIS approval is not yet the final scope state. PAL 2026-04 states that the change is not part of the HRSA-approved scope until scope verification is completed and HRSA sends the subsequent NoA or NLD documenting inclusion in scope.
FROM POLICY TO ACTION
Regulatory updates should change the workflow, not just the documentation.
RIEL’s direction is to translate policy changes into configured terminology, rules, deadlines, findings and assigned actions. The goal is a living operating model that can evolve as HRSA guidance evolves.
Current source and effective-date context stays attached to operational rules.
Discrepancies point to current guidance instead of superseded citations.
Policy signals become tasks, deadlines, evidence requirements and role-based follow-up.
HRSA Policy Manual
PAL / Guidance
EHB Changes
RIEL regulatory layer
Source · Rule · Effective Date · Module Impact
Form 5A
Services
Services
Form 5B
Sites
Sites
Change in Scope
Workflow
Workflow
Tasks
Alerts
Evidence
Findings
Guidance
THE FULL SCOPE OF PROJECT PICTURE
Scope is broader than Forms 5A and 5B.
HRSA identifies five elements that define a health center’s Scope of Project. RIEL currently operationalizes the service, site and provider dimensions and is designed to connect those records to the workflows that depend on them.
01Medically underserved populationsScope element
02Service areaScope element
03ServicesRIEL modeled
04SitesRIEL modeled
05ProvidersRIEL modeled
Scope of ProjectServices · Sites · Providers
CredentialingProvider readiness
PrivilegingClinical authorization
EnrollmentPayer readiness
Operational ReadinessTasks · Evidence · Follow-up
PRIMARY SOURCES
Built against the current HRSA framework.
RIEL’s Scope of Project alignment is based on HRSA’s published guidance, not on a static checklist copied into software and forgotten until the next audit cycle.
Program Assistance Letter
PAL 2026-04: Health Center Program Scope of Project System Improvements
Published by HRSA on August 14, 2026. Covers CIS process consolidation, Form 5A and Form 5B system improvements and the November EHB transition.
Open official PDF ↗Policy Manual
Health Center Program Scope of Project Policy Manual
HRSA’s primary Scope of Project policy source, covering scope elements, services, sites, providers, agreements and Change in Scope requirements.
Open official PDF ↗HRSA Resource Hub
Scope of Project Resources
HRSA’s current hub for Scope of Project policies, Change in Scope resources, Form 5A materials, site guidance and supporting tools.
Open HRSA resources ↗Important: RIEL Healthcare Solutions is an independent software provider and is not affiliated with, endorsed by, or certified by HRSA or the U.S. Department of Health and Human Services. RIEL supports operational readiness and workflow management; health centers remain responsible for interpreting applicable requirements, maintaining accurate submissions and making final compliance decisions in consultation with HRSA and their Project Officer when appropriate.
SEE THE WORKFLOW, NOT ANOTHER SLIDE DECK
Bring your real Scope of Project scenario to RIEL.
Walk through services, sites, agreements, CIS classifications and readiness signals using the same connected operational model your team uses for credentialing, privileging, enrollment and HRSA readiness.