Preparing for a Virtual Operational Site Visit
During the 2020 global pandemic of the novel Coronavirus, HRSA has suspended in-person Operational Site Visits (OSVs) through the end of 2020. OSVs are an important part of HRSA’s efforts to oversee the Health Center Program and “provide an objective assessment and verification of the status of each Health Center Program awardee or look-alike’s compliance with the statutory and regulatory requirements of the Health Center Program” (HRSA Site Visit Protocol). In an effort to continue this oversight while being sensitive to the increased stress health centers have upon them, the Bureau of Primary Health Care (BPHC) has instituted “Virtual Operational Site Visits”, or “VOSVs”.
These VOSVs maintain a similar format (three days of interviews, tours, and document review) but are completed remotely using video conferencing tools (GoToMeeting) and a file-sharing platform (Citrix ShareFile).
Though much of the process remains unchanged, one of the biggest differences between the OSV and the VOSV is the inability to form the rapport between the reviewers and staff. Health centers should do as much as possible to make it easy to get to know the team and streamline the process for the review team to know who to talk to for each compliance area. We recommend sharing a “Picture Directory” with all of the staff on the document so the team can know which areas they are responsible for and how to get in touch with each person.
Also, another difference with the Virtual Operational Site Visits is that the HRSA team asks for the documents to be named with their naming convention as outlined in their modified Site Visit Protocol Document List (This is frequently changing and will be provided by the HRSA Project Officer). Health centers should make sure they are paying special attention to what the documents are to be named and organized. The goal is to have reviewers be able to find the documents they are looking for quickly so be careful to name the documents exactly as requested.
Since the reviewers will not be able to review documents in-person, health centers should clarify with the reviewers how they would like to review documents like fiscal records, patient medical record documentation, and credentialing and privileging files. Most reviewers will likely be satisfied with the health center physically holding the documents up to the screen during a video call and will not ask you to scan in all of the paper documents. But make sure you and the reviewer are on the same page before your VOSV begins.
A common part of in-person OSVs is the tour of multiple health center sites. In a VOSV, this part is modified. Some HRSA review teams will ask you to create a video tour that is pre-recorded while others will ask for a picture slideshow, and still others might ask you to bring a laptop with a video camera around the site as they share their video over video conference call. Make sure you verify with the HRSA review team what method they would like you to use.
And finally, flexibility is probably the most important attribute to focus on during the VOSV. Many HRSA staff, consultant reviewers, and health centers staff have never completed a VOSV before and guidance is changing as lessons are learned. Work to be understanding and flexible as you work with your reviewers and HRSA team and seek to make the process as easy and stress-free as possible. As always, working to guide your health center toward a state of continuous HRSA compliance will be extremely helpful as you work to prepare for your next OSV-whether it will be virtual or in-person.