Making it Easy to Understand Who’s Eligible for HRSA’s School-Based Health Center Capital Program

The Affordable Care Act has made it especially hard to figure out who’s eligible for a program. This week, the “Affordable Care Act: Grants for School-Based Health Center Capital Program” is our star. The announcement says that eligible applicants must “Be a school-based health center or a sponsoring facility of a school-based health center as defined in 4101(a)(6) of the Affordable Care Act [. . .]”

Once you track that section down, however, you find this: “(6) DEFINITIONS- In this subsection, the terms ‘school-based health center’ and ‘sponsoring facility’ have the meanings given those terms in section 2110(c)(9) of the Social Security Act (42 U.S.C. 1397jj(c)(9)).” So it’s off to find the Social Security Act. Eventually you’ll find:

In general.—The term “school-based health center” means a health clinic that—

(i) is located in or near a school facility of a school district or board or of an Indian tribe or tribal organization;

(ii) is organized through school, community, and health provider relationships;

(iii) is administered by a sponsoring facility;

(iv) provides through health professionals primary health services to children in accordance with State and local law, including laws relating to licensure and certification; and

(v) satisfies such other requirements as a State may establish for the operation of such a clinic.

Note that these five subsections describe only what school-based health center means “In general.” What would a specific definition be? Notice too that the act doesn’t mention whether this program applies only to K-12 schools, or if universities count. We’re choosing to interpret Local Education Agencies (LEAs) and their subsidiaries as eligible, since IHEs aren’t mentioned and “school district” generally implies LEAs. If you have any reason to think otherwise, let us know in the comments.

This isn’t the first time we’ve investigated curious, obfuscatory eligibility requirements, and I doubt it will be the last.

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