HRSA 330 Eligibility Requirements

Statutory Eligibility Under Section 330

Section 330 of the Public Health Service Act (42 U.S.C. § 254b) establishes the legal foundation for the Health Center Program. To be eligible for Section 330 funding, an organization must satisfy statutory requirements that fall into four broad categories: organizational structure, governance, services, and need. These requirements are not discretionary — they are embedded in the statute and cannot be waived by HRSA.

Before investing in a Section 330 application, organizations should conduct an honest self-assessment against every requirement described below. The most common reason new applicants fail is not a weak narrative — it's a fundamental misalignment between the organization's current structure and what Section 330 requires. If you identify gaps, it is almost always better to address them before applying rather than trying to explain them away in the application.

Organizational Structure Requirements

Nonprofit or Public Entity Status

Section 330 applicants must be either a public entity (state or local government, tribal government, or tribal organization) or a private nonprofit organization with tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. For-profit entities are not eligible. This requirement applies to the applicant organization itself, not to subcontractors or partners.

If you are a private nonprofit, you must be able to demonstrate 501(c)(3) status with a current IRS determination letter. Organizations with pending 501(c)(3) applications are generally not eligible until the determination is final. Public entities must document their legal authority through enabling legislation, charter, or equivalent documentation.

Domestic Organization

The applicant must be a domestic organization located in the United States, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, American Samoa, Guam, the Northern Mariana Islands, the Republic of Palau, the Federated States of Micronesia, or the Republic of the Marshall Islands. Services must be provided within these jurisdictions.

Board of Directors Composition

The board governance requirement is one of the most distinctive — and most frequently problematic — aspects of Section 330 eligibility. The statute requires a specific board composition that gives patients a controlling voice in health center governance. This is not a suggestion or best practice: it is a statutory requirement that HRSA verifies during every Operational Site Visit.

51% Patient Majority Requirement

A minimum of 51% of board members must be registered patients of the health center who receive services at the health center and who, as a group, reasonably represent the patient population served. “Reasonably represent” means the patient board members should reflect the demographic, socioeconomic, and geographic characteristics of the patients served — including race/ethnicity, gender, age range, and special populations (homeless, agricultural workers, etc.).

HRSA verifies patient majority by reviewing board rosters against the patient database. If a patient board member has not had a visit within the past 24 months (or within the timeframe specified in the health center's patient definition policy), they may not count toward the 51% threshold. This is a common compliance trap: health centers recruit patient members who then stop coming in for care, gradually eroding the majority.

Non-Patient Board Members

The remaining board seats (up to 49%) should include individuals with skills and expertise relevant to health center operations — finance, legal, business management, healthcare delivery, and community affairs. HRSA encourages boards to recruit non-patient members who bring complementary expertise that supports effective governance and financial oversight.

Board Authority Requirements

The board must hold specific authorities that cannot be delegated to staff. These include:

• •Approval of the annual budget and grant applications
• •Selection and dismissal of the CEO/Executive Director (including performance evaluation)
• •Approval of the sliding fee discount schedule
• •Establishment of general policies for the health center, including hours of operation and services provided
• •Approval of patient grievance policies
• •Adoption of health center bylaws
• •Approval of quality improvement and quality assurance plans

Board minutes must document the exercise of these authorities. HRSA reviewers will look at meeting minutes from the past 2–3 years during an OSV to verify that the board is actively governing — not rubber-stamping staff decisions.

Required Registrations

Before submitting any Section 330 application, organizations must complete several federal registration processes. These registrations can take weeks or months, so they must be initiated well in advance of any NOFO deadline.

A lapsed SAM.gov registration will prevent you from receiving any federal payments and can make your application ineligible for review. Set calendar reminders to renew at least 30 days before expiration. Many health centers assign SAM.gov renewal to a specific staff member and include it on their compliance calendar.

FQHC vs. FQHC Look-Alike

Understanding the distinction between FQHC and FQHC Look-Alike (LAL) status is critical for organizations considering whether to pursue Section 330 funding. Both designations require compliance with the same 19 Program Requirements, but they differ significantly in funding, benefits, and the path to achieve them.

Many organizations pursue FQHC Look-Alike designation first to demonstrate compliance with the 19 Program Requirements, build operational capacity, and access enhanced reimbursement — then apply for Section 330 funding when a New Access Point NOFO is released. This is a well-established pathway and HRSA reviewers view LAL experience favorably when evaluating NAP applications.

Service Area Requirements

Section 330 grantees must serve a defined geographic service area that meets one or both of the following designations:

• •Medically Underserved Area (MUA): A geographic area (county, group of contiguous counties, urban census tract) designated by HRSA as having a shortage of personal health services based on the Index of Medical Underservice (IMU) score.
• •Medically Underserved Population (MUP): A specific population group within a defined area that faces economic, cultural, or linguistic barriers to healthcare access, regardless of the area's overall designation.

Organizations can check current MUA/MUP designations using HRSA's Health Resources and Services Administration Data Portal. If your target service area does not have an active designation, you may need to submit a new MUA/MUP application to HRSA, which can take 6–12 months for approval.

Needs Assessment

All Section 330 applicants must conduct a comprehensive needs assessment that documents the health status and healthcare access barriers in the proposed service area. The needs assessment should include:

• •Demographic profile of the target population (income levels, insurance status, race/ethnicity, language)
• •Health status indicators (chronic disease prevalence, maternal/child health outcomes, behavioral health burden)
• •Provider-to-population ratios and geographic access barriers
• •Existing safety net resources and gaps in coverage
• •Input from the target community (surveys, focus groups, stakeholder interviews)

The needs assessment is not a one-time requirement. HRSA expects health centers to update their needs assessment periodically — at minimum when applying for Service Area Competition renewals — and to use needs assessment data to drive service planning and resource allocation decisions. Board members should be able to articulate the key needs the health center addresses.

Required Services

Section 330 grantees must provide or arrange for the following categories of services, either directly or through established referral arrangements with documented agreements:

• •Primary medical care — including preventive care, chronic disease management, and acute care
• •Diagnostic laboratory and radiology services
• •Behavioral health — mental health and substance use disorder services
• •Emergency medical services (via referral arrangement)
• •Pharmaceutical services (on-site pharmacy, contract pharmacy, or prescription assistance)
• •Enabling services — case management, transportation, interpretation/translation, outreach, patient education

Services do not need to be provided at every site, but the health center must demonstrate that all required services are accessible to patients within the service area. Referral arrangements must be documented with formal written agreements that specify the scope, availability, and payment terms. HRSA reviewers pay close attention to whether referral agreements are current and whether the health center tracks referral completion rates.

Special Population Funding Streams

If an organization seeks funding under one of the special population authorities (Migrant Health 330(g), Health Care for the Homeless 330(h), or Public Housing Primary Care 330(i)), additional eligibility requirements apply:

Migrant Health Centers — 330(g)

Applicants must demonstrate a significant presence of migratory and seasonal agricultural workers (MSAWs) and their families in the service area. The needs assessment must include MSAW population estimates, seasonal patterns, occupational health hazards, and access barriers specific to agricultural worker populations. Services must include outreach to camps and work sites, occupational health screening, and culturally and linguistically appropriate care.

Health Care for the Homeless — 330(h)

Applicants must document the scope of homelessness in the service area using point-in-time count data, continuum of care information, and local homeless services data. Services must be delivered in settings accessible to people experiencing homelessness — including shelters, transitional housing, drop-in centers, and street outreach. The program must include a substance abuse treatment component.

Public Housing Primary Care — 330(i)

Applicants must have a formal arrangement with a public housing authority (PHA) and must serve residents of public housing developments. The health center must deliver services at or near the public housing site, and board membership should include public housing residents.

Eligibility Self-Assessment Checklist

Before committing resources to a Section 330 application, verify that your organization can affirm each of the following:

If you meet all of the above criteria, you have the foundational eligibility to pursue Section 330 funding. The next step is understanding the NOFO cycle and application process — covered in the Application & NOFO Guide. If you are not yet ready, consider pursuing FQHC Look-Alike designation as a development pathway while you build the organizational capacity needed for a competitive application.

For a broader perspective on the federal requirements that apply to all HRSA awards, see our guide to 2 CFR 200 compliance and the SAM.gov registration guide.