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

Washington, DC US
February 7, 2023 to February 8, 2023

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.

At the start of the COVID-19 pandemic, HRSA transitioned and re-focused its compliance assessment efforts for Federally Qualified Health Centers (FQHCs) to a virtual process that mirrored the in-person reviews.  Almost three years later, it appears that HRSA may transition the Operational Site Visit (OSV) process once again, moving towards an approach that strives for both compliance and excellence by combining aspects of the “live” (virtual or in-person) process with desk audits and pre-OSV technical assistance sessions on the Health Center Program Requirements.  Regardless of the specific process used for your OSV, compliance with health center program requirements is a vital component of 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.

All forms of the OSV process revolve around the Health Center Program Compliance Manual, a consolidated resource to assist FQHCs 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.

To assist in conducting a “hands-on” compliance assessment, HRSA reviewers utilize the Site Visit Protocol, which aligns with the Manual and reflects an objective assessment tool. HRSA’s most recent Protocol, which is effective for all OSVs (and Look-Alike certification site visits), clarifies the documentation requirements and assessment methodologies used by HRSA to verify compliance.

As in the past, HRSA maintains 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 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, 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? Does your sliding fee discount schedule apply to all in-scope services and have you implemented mechanisms to ensure input from your Board members when establishing the sliding fee discount schedule and nominal fee and conducting 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, including but not limited to your procurement processes, sufficient for purposes of federal accountability and good stewardship of public funds?
  • 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 FTLF for this training exploring:

  • 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, 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.
Course summary
Course opens: 
Course expires: 
Event starts: 
02/07/2023 - 10:00am EST
Event ends: 
02/08/2023 - 5:30pm EST


Washington, DC or FTLF Virtual Classroom
Tuesday, February 7-Wednesday, February 8, 2023
*Agenda times are all ET and subject to change*

Day 1

Tuesday, February 7, 2023
10:00 a.m.-5:30 p.m. ET
10:00-10:15 a.m.Welcome and Overview of the Training
10:15-11:30 a.m.The Heart of Your Health Center Project: Needs, Services & Continuity of Care – Part 1 (Chapters 4, 7, 8) 
11:30-11:45 a.m.Break
11:45 a.m.-12:45 p.m.The Heart of Your Health Center Project: Needs, Services & Continuity of Care – Part 2 (Chapters 3, 6, 14)
12:45-1:45 p.m.Break
1:45-2:45 p.m.Quality is Key (Chapter 10)
2:45-3:45 p.m. Personnel Dynamics – Ensuring Appropriate Key Management and Clinical Staff (Chapters 11 & 5)
3:45-4:00 p.m.Break
4:00-5:30 p.m. Building Blocks of Fiscal Viability and Internal Controls: Budgeting and Financial Management (Chapters 17, 15) 

Day 2

Wednesday, February 8, 2023
10:00 a.m.-5:30 p.m. ET
10:00-10:15 a.m.Day 1 “Parking Lot” and Other Outstanding Questions
10:15-11:30 a.m.Building Blocks of Fiscal Viability and Internal Controls: Contracts, Subawards and Standards of Conduct (Chapters 12, 13) 
11:30-11:45 a.m.Break
11:45 a.m.-1:00 p.m.Ensuring the Core Mission: Making Care affordable While Maximizing Reimbursement – Part 1 (Chapters 16 & 9)
1:00-2:00 p.m.Break
2:00-3:15 p.m.Ensuring the Core Mission: Making Care affordable While Maximizing Reimbursement – Part 2 (Chapters 16 & 9) 
3:15-3:30 p.m.Break
3:30-5:00 p.m.The “Community” in Community Health Center: The Governing Board of Directors (Chapters 19 & 20)
5:00-5:15 p.m.It's All About the Data (Chapter 18)
5:15-5:30 p.m.Q&A and Wrap-Up
FTLF Training Center
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Washington, DC 20036
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AC Hotel by Marriott (0.1 mi)
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Washington, D.C. 20036

St. Gregory Hotel Dupont Circle** (0.2 mi)
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Washington, D.C. 20036

Hyatt Place Washington DC/Georgetown/West End** (0.3 mi)
FTLF Discounted Rate Group Code 89073
2121 M St NW
Washington, D.C. 20037

Hilton Garden Inn Washington DC/Georgetown Area** (0.3 mi)
2201 M St NW
Washington, DC 20037

West End Washington DC, Tapestry Collection by Hilton (0.3 mi)
1121 New Hampshire Ave NW
Washington, D.C. 20037

Washington Marriott Georgetown (0.4 mi)
1221 22nd St NW
Washington, D.C. 20037

Embassy Suites by Hilton Washington DC Georgetown (0.4 mi)
1250 22nd St NW
Washington, D.C. 20037

** Discounted Rate available through FTLF link



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]

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This training will not be recorded for later viewing, as we would like attendees to be comfortable and candid, sharing their experiences and asking scenario-based questions. The discourse between the attorneys and participants is a valued part of each training.

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