HRSA’s compliance assessment efforts are a “mainstay” of the Health Center Program (HCP).  Conducted at least once per project period, all health centers are subject to an Operational Site Visit (OSV) to determine their ongoing compliance with the HCP Requirements that establish the foundation and framework of every health center’s particular project. For new health centers – whether new grantees or new Federally Qualified Health Center (FQHC) Look-Alike entities – the OSV is a vital component in obtaining initial designation or certification. After a brief respite, HRSA has begun ramping up the OSV process, utilizing the traditional 3-day process with a focus on document reviews and staff and board member interviews.  

In Fall 2025, HRSA released revised guidance to lead health centers through the OSV process.  In particular, for the first time in several years, HRSA issued modified versions of the HCP Compliance Manual and HCP Site Visit Protocol (SVP), incorporating new and amended requirements that, in part, reflect new grant terms, executive orders and other Administration directives. As with prior versions, the revised Manual is a consolidated resource to assist health centers in understanding, demonstrating, and operationalizing compliance. The Manual incorporates an “ongoing compliance” approach by addressing each requirement’s statutory and regulatory bases, the key elements of compliance that collectively form the framework of every health center’s project, and areas for which health centers maintain discretion. Similarly, all assessment processes are guided by the revised SVP, which aligns with the HCP Compliance Manual and forms the basis for an objective compliance assessment, clarifying documentation requirements and assessment methodologies.

Compliance with HCP Requirements in both documentation and practice is essential to a health center’s daily operations … and non-compliance findings may result in legal consequences that significantly impact operations and your ability to serve your patient populations and your community at large.

Regardless of any changes to the assessment process and guidance, HRSA maintains an expectation of 100% ongoing compliance with the HCP Requirements – both in your documentation and your daily operations. Is your health center prepared to meet this challenge? Have you reviewed the most recent HRSA guidance and assessment processes with an eye toward shoring up your own operations and establishing your HRSA compliance work plan? For example,

• Is your Form 5A up to date, based on HRSA’s definitions for services and modes of delivery?
• Do you have written contracts and referral agreements in place for services listed in columns II and III of Form 5A, and do they include all required provisions?
• Are all members of your clinical staff (including other clinical staff members such as dental and medical assistants and community health workers) appropriately credentialed and privileged?
• Does your quality improvement system meet all current standards?
• Do you have systems in place to assess all patients for income and family size? Does your sliding fee discount schedule apply to all in-scope services and have you implemented mechanisms to ensure input from your Board members and patients when establishing the sliding fee discount schedule and nominal fee, as well as when conducting an effective evaluation of the program overall?
• Do you have billing and collection policies that address the waiver / reduction of payments and other processes that help strike the balance between maximizing reimbursement and maintaining optimum access?
• Is your financial management system, including but not limited to your procurement processes, sufficient for purposes of federal accountability and good stewardship of public funds, consistent with the new administrative requirements in 2 CFR Part 200?
• Is your budget constructed to account for all expenses and revenues?
• Is your Board of Directors independently exercising all required authorities, without limitation, and do you have documentation to verify compliance?

Join us for this training exploring:

• The differences between the revised OSV-related guidance, including the Compliance Manual and the SVP, and prior versions, including the incorporation of new grant terms, executive order requirements and Administration directives;
• How to use the revised Compliance Manual, SVP, and other HRSA-issued compliance guidance to prepare for your compliance assessment, including discussion of the elements of the HCP Requirements, the documentation and assessment methodologies required to verify compliance with each, and where health centers retain explicit discretion and flexibility;
• How the legal requirements intersect with the reviewers’ interpretations;
• Key high-risk areas from recent compliance reviews; and
• Compliance tips from our presenters’ years of experience working first-hand with hundreds of health centers prior to, during, and after their OSVs.