In August 2017, HRSA issued the final Health Center Program Compliance Manual, providing a streamlined and consolidated resource to assist health centers in understanding and demonstrating compliance with the Program Requirements. The Manual replaces several Policy Information Notices (PINs) and Program Assistance Letters (PALs), consolidating guidance into one document addressing the elements of the Program Requirements, methodology for documenting compliance, and specific areas of flexibility. HRSA also indicated it is “field testing” a new assessment protocol aligned with the Manual, which, once final, will replace the current Health Center Program Site Visit Guide for assessing compliance during Operational Site Visits (OSVs).

 

Of importance, the Manual was effective immediately upon publication. What does that mean for health centers with upcoming grant applications and OSVs? While the requirements outlined in the Manual continue to reflect the statutory and regulatory mandates, the Manual incorporates a new approach to “everyday “compliance, providing both specific steps to demonstrate compliance and explicit areas where health centers retain discretion to tailor their programs appropriately. Join FTLF Attorneys, Marcie Zakheim, Molly Evans and Scott Sheffler for this five-part webinar series as they explore key differences between the prior guidance, the Manual and implications for health center operations. Participants will discuss “tips” to implement specific compliance steps and utilize the discretion afforded their specific projects.