Deciphering the Operational Site Visit: Legal Requirements and Practical Tips for a Successful OSV (Virtual)

September 7, 2022 to September 8, 2022

Looking for the February 2023 OSV training?  Please click here

As a result of the COVID-19 pandemic, HRSA transitioned and re-focused its compliance efforts for Federally Qualified Health Centers (FQHCs) to a virtual compliance assessment process.  Despite this change to a virtual platform, the review process itself strives to mirror the onsite process. As such, compliance with health center program requirements is still a vital component of a health center’s daily operations.

Similar to the on-site process, the virtual Operational Site Visit (OSV) revolves around the Health Center Program Compliance Manual, a consolidated resource to assist FQHCs in understanding, demonstrating, and operationalizing compliance. The Manual, which supersedes most (but not all) prior guidance, incorporates a new approach to “everyday compliance” by addressing each requirement’s statutory and regulatory basis, the key elements of compliance that collectively form the framework of every health center’s project, and areas for which health centers maintain discretion.

To assist in conducting a “hands-on” compliance assessment, HRSA reviewers utilize the Site Visit Protocol, which aligns with the Manual and reflects a more objective assessment tool than prior review guides. HRSA’s most recent Protocol clarifies the documentation requirements and assessment methodologies used by HRSA to verify compliance during both OSVs and “desk audits” of applications for grant project period and FQHC look-alike designation renewals.

As in the past, there is an expectation of 100% ongoing compliance with the Health Center Program Requirements. Is your health center prepared to meet this challenge? Have you reviewed the most recent HRSA guidance and assessment processes with an eye towards 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 service definitions and correct 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, including sliding fee discounts and provisions under 45 CFR Part 75?
  • Are members of your clinical staff (including staff members such as dental assistants, 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? Have you implemented mechanisms to inform patients about the sliding fee discount program and to conduct an effectiveness evaluation of the program?
  • 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 sufficient for federal accountability purposes?
  • Is your Board of Directors independently exercising all required authorities, and do you have documentation to verify compliance?

Join FTLF for this training exploring:

  • The virtual OSV process and how it differs from (and is the same as) the onsite process;
  • How to use the Compliance Manual, the most recent Site Visit Protocol and other HRSA-issued compliance guidance to prepare for your OSV, including discussion of the elements of the programmatic requirements and the documentation and assessment methodologies required to verify compliance with each, as well as areas 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.

Target Audience

  • Health Center Executive Staff
  • Clinical Leadership
  • Quality and Credentialing/Privileging Staff
  • Financial Leadership and Staff
  • Compliance Officers
  • Administrative / Operations Leadership and Staff
  • Board members
  • Other Staff assisting with HRSA compliance and/or OSV preparation

Please Note: This training is limited to community health centers and look-alikes. If you are not affiliated with a health center and would like to attend, please contact us.

Learning Objectives

After this training, you will be able to:

  • Identify the elements of the HRSA program requirements addressed in the Manual and the Protocol.
  • Describe the specific documentation and assessment process necessary to demonstrate compliance and areas where health centers retain discretion.
  • Discuss the newest compliance tips for all phases of the HRSA compliance review (before, during, and after) and use such tips to establish your health center’s HRSA compliance workplan.
Course summary
Available credit: 
  • 11.00 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
09/07/2022 - 10:00am EDT
Event ends: 
09/08/2022 - 5:00pm EDT


FTLF Virtual Classroom or Washington, DC
Wednesday, September 7, 2022 - Thursday, September 8, 2022

*All specific agenda times are ET and subject to change*

NOTE: The two sessions listed below will NOT be addressed in the workshop and will be provided via pre-recorded webinar prior to the on-site training. Please review the webinars prior to arrival and come prepared with your questions! The webinars can be accessed by clicking the gray "Take Course" button on either the "Overview" or "Register" tab once you have registered for the course.

  • Introduction to the Health Center Program Compliance Manual and HRSA Review Process
  • Working within the “Box”: Key Elements and Requirements of Scope of Project

Day 1

Wednesday, September 7, 2022       
10:00 am - 5:30 pm ET
10:00 am - 10:15 amIntroduction to the Training
10:15 am - 11:30 am
The "Community" in Community Health Center: The Governing Board of Directors
  • Chapter 19: Board Authority
  • Chapter 20: Board Composition
11:30 am - 11:45 amBreak
11:45 am - 1:00 pm
The Heart of Your Health Center Project: Need, Services & Continuity of Care - Part I
  • Chapter 3: Needs Assessment
  • Chapter 4: Required & Additional Health Services
  • Chapter 6: Accessible Locations and Hours of Operation
  • Chapter 7: Coverage for Medical Emergencies During and After-Hours
  • Chapter 8: Continuity of Care & Hospital Admitting
  • Chapter 14: Collaborative Relationships
1:00 pm - 2:00 pmBreak
2:00 pm - 3:00 pm
The Heart of Your Health Center Project: Need, Services & Continuity of Care - Part 2
3:00 pm - 4:00 pm
Quality is Key
  • Chapter 10: Quality Improvement/Assurance
4:00 pm - 4:15 pmBreak
4:15 pm - 5:30 pm
Personnel Dynamics - Ensuring Appropriate Management and Staff
  • Chapter 11: Key Management Staff
  • Chapter 5: Clinical Staffing

Day 2

Thursday, September 8, 2022       
10:00 am - 5:15 pm ET
10:00 am - 11:30 am
Internal Controls and Ensuring Fiscal Viability - Part 1
  • Chapter 15: Financial Management & Accounting Systems
  • Chapter 17: Budget
  • Chapter 12: Contracts and Sub-awards
  • Chapter 13: Conflict of Interest Policy
11:30 am - 11:45 amBreak
11:45 am - 1:00 pmInternal Controls and Ensuring Fiscal Viability - Part 2
1:00 pm - 2:00 pmBreak
2:00 pm - 3:30 pm
Ensuring the Core Mission: Making Care Affordable While Maximizing Reimbursement - Part 1
  • Chapter 16: Billing and Collection
  • Chapter 9: The Sliding Fee Discount Program
3:30 pm - 3:45 pmBreak
3:45 pm - 4:45 pm
Ensuring the Core Mission: Making Care Affordable While Maximizing Reimbursement - Part 2
4:45 pm - 5:00 pm
It's All Up with Data 
  • Chapter 18: Program Monitoring and Data Reporting Systems
5:00 pm - 5:15 pmQuestions & Wrap-Up


This live, interactive training will take place in FTLF's Virtual Classroom, hosted by Zoom.  Should you have any technical questions or would like more information, please contact us at or 1-855-200-3822.


A Partner in the firm’s health law practice group, Molly advises health centers on the management of clinical, employment and workforce related risks, with a particular focus on professional liability, Federal Tort Claims Act, and HIPAA matters. From her experience as both a private attorney and in-house counsel, Molly knows the importance of managing liability and risk issues in mission-driven organizations. [Full Bio]


Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted is a national authority in the area of federal grants, particularly in the health and community service spheres. He advises clients on all aspects of program requirements, including issues such as cost-based reimbursement, governance and the never-ending list of grant administration matters. Ted’s expertise in financial, cost reporting, reimbursement, and administrative issues is widely recognized and he routinely handles government audits, internal investigations, and litigation. [Full Bio]


A Partner at the firm, Marcie specializes in health care law, particularly in the areas of federal grants, grant-related requirements and grants management related to the federal health center program. Health centers turn to Marcie as a resource for knowing not only the letter of the law, but also the likely interpretation of requirements by federal policymakers, including the Health Resources and Services Administration (HRSA). [Full Bio]

Participants can earn up to 12.00 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


  • Prerequisites: None 
  • Target Audience: Health Center Executive Staff, Clinical Leadership, Quality and Credentialing/Privileging Staff, Financial Leadership and Staff, Compliance Officers, Board members, Other Staff assisting with HRSA compliance and/or OSV preparation
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based

Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website (formerly

Available Credit

  • 11.00 Certificate of Attendance


Please login or register to take this course.


This training will be recorded for later viewing, and attendees will receive a copy of the recording after the event.

Registration Fees

Virtual Registration
Early Registration
(Through May 31)
Discounted Registration
(June 1 - August 9)
Regular Registration
(August 10 - September 7)

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Bring your team! Discounts are available for groups of three (3) or more individuals from the same organization. Please contact us to process your registration.

Groups of 3 - 6
Groups of 7 - 10
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  • For yourself: login to your account and register with your personal information
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Cancellation/Transfer Policy

All cancellation or transfer requests must be received in writing at Requests for refunds or transfers for in-person events will be granted according to the following schedule:

  • 30 or more days prior to the event, requests for a full refund or a transfer, minus a $75 administrative fee, will be granted.
  • Between 11 to 29 days prior to the event, requests for cancellations will be granted a 50% refund and requests for transfers will be granted, space permitting and subject to a transfer fee.
  • Within 10 days of the event start date, no requests for refunds or credits will be granted. At FTLF's discretion, late transfers may be granted, space permitting and subject to a transfer fee.

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at


Yes, you can transfer to attend in-person, providing there is an open seat.  Any additional registration cost is due at the time of transfer.  All transfer requests must be submitted in writing.

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at

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