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Behavioral Health Care for Mobile Populations: Risk Management Considerations

In recognition of the importance of behavioral health as a component of quality health care delivery, HRSA requires health centers to provide these services to their patient population. These are services that are difficult for many MHCs to provide onsite so they must be contracted to outside providers. Behavioral health services may include, but are not limited to, counseling for mental health issues (e.g., depression, anxiety) and substance abuse (e.g., alcohol, recreational drugs). Health centers need to be aware of the special requirements imposed by HIPAA on medical records generated by the provision of behavioral health services, and consider the impact on FTCA coverage of referring patients to outside and/or off-site providers.

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