Over the last few years, HRSA has significantly increased its scrutiny of health centers’ compliance, first with development of the “nineteen (19) health center program requirements” and now with the recent issuance of the Health Center Program Compliance Manual.  The Manual offers health centers a streamlined and consolidated resource to assist them in achieving compliance – both on paper as well as in practice – by addressing the elements of each program requirement, criteria for demonstrating compliance, and specific areas of health center flexibility. In practice, the Manual incorporates a new approach to “everyday compliance,” providing both specific compliance standards and explicit areas where health centers retain discretion to tailor their programs appropriately.

Eventually, the Compliance Manual along with an as of yet unpublished assessment protocol will form the new basis for the Operational Site Visits (OSVs). While the “tools” may change, the impact on the health center operation remains the same:

• Do you have written agreements in place for services provided via contract and/or formal referral and do your agreements include all required provisions?
• Are your providers appropriately credentialed and privileged and do your quality improvement systems meet all current standards?
• Have you fully implemented the sliding fee discount program requirements?
• Have your billing and collection policies struck the balance between maximizing reimbursement and maintaining optimum access?
• Is your financial management system sufficient for accountability purposes?
• Is your Board of Directors exercising all of its authorities and meeting other governance requirements?

Given the potential consequences of non-compliance (including draw-down restrictions and re-competition of your grant), it is crucial that every health center prepare itself by reviewing its knowledge and implementation of all core requirements as described in the new Compliance Manual. 

Join Marcie Zakheim from FTLF and Warren Brodine, trusted health center advisor, for this hands-on training as they walk health centers through the requirements, compliance elements and areas of discretion addressed in the Compliance Manual (and the OSV review process in general), identify key hotspots (both old and new) that have emerged from the field regarding governance, administration and finance, and offer participants “tricks of the trade” from our presenters’ years of experience working with health centers. Whether or not you have an OSV on the horizon, this is a must attend workshop!