Health Center Regulatory Issues

HRSA Issues Revised Site Visit Guide to Include Requirements from New Policies

HRSA Issues Revised Site Visit Guide to Include Requirements from New Policies

On November 24, 2014, the Health Resources and Services Administration (HRSA) issued a revised Health Center Program Site Visit Guide (the Guide), effective December 1, 2014. The updated Guide incorporates revisions and clarifications that were initially included in several HRSA policies and guidance documents issued during calendar year 2014, including Policy Information Notice (PIN) 2014-01: Health Center Program Governance and PIN 2014-02: Sliding Fee Discount and Related Billing and Collections Program Requirements. Specifically, the Guide incorporates the following revisions:

  • Requirement #2 (Required and Additional Services) was revised to clarify that the compliance assessment of required and additional services should focus solely on whether (i) the health center is providing all required services; and (ii) for all in-scope services provided via written contract or formal, written referral agreement (Columns II or III of Form 5A – Services), whether required or additional, there is an appropriate agreement in place. The accuracy of a health center’s scope of project with respect to Form 5A should be documented under Requirement #16 (Scope of Project), while findings regarding whether services are available under an appropriately structured sliding fee discount program regardless of the mode of delivery (consistent with PIN 2014-02) should be documented under Requirement #7 (Sliding Fee Discounts).
  • Requirement #7 (Sliding Fee Discounts) was updated to include questions to align and assess compliance with PIN 2014-02.
  • Requirement #12 (Financial Management and Control Policies) was updated to delete all references to “Financial Recovery Plans” since HRSA no longer requires or utilizes them for health center monitoring. For additional information on this change, please see the Policy Shop blog from September 9, 2014, entitled “HRSA’s September 3, 2014 Weekly Digest Includes Clarifications Regarding HRSA’s Role in Monitoring. [Susan – please add link to the Policy Shop blog from September 9]
  • Requirement #13 (Billing and Collections) was updated to include questions to assess compliance and align with PIN 2014-02.
  • Requirement #17 (Board Authority) was revised to clarify that all organizations must now meet monthly, regardless of prior waiver status, consistent with PIN 2014-01 (which eliminated the monthly meeting requirement for special population only health centers). Because the January 2014 version of the Guide was issued around the same time as PIN 2014-01, it allowed health centers with previously approved monthly meeting waivers to demonstrate that they had “begun or completed a plan to transition the board to holding monthly meetings,” rather than verifying full compliance with the new requirement. At this point in time, HRSA expects that all centers are (or should be) compliant with the meeting requirement and thus, this qualification was eliminated from the new version of the Guide.

As noted above, HRSA has indicated that the updated Guide is effective as of December 1, 2014; accordingly, review teams conducting Operational Site Visits (OSVs) after that date will utilize the November 2014 version as the assessment framework. To ensure compliance with the most current requirements, it is important that all health centers review the updated Guide and revise their particular policies and procedures as necessary.