ACH submitted comments generally supporting HRSA’s proposed updates to the Health Center Program Scope of Project Policy Manual while raising concerns about telehealth restrictions and administrative burden. ACH recommended greater flexibility for providing telehealth—particularly behavioral health services—to patients outside a health center’s service area, clearer geographic eligibility standards and protections for seasonal or temporarily absent residents. The organization also urged HRSA to reconsider requiring every contract and cooperative agreement to satisfy the same seven “on behalf of” criteria, warning that the approach could prevent health centers from partnering with outside organizations to deliver essential services.