HRSA's Focus on Continual Compliance

HRSA has built-in several elements to the Operational Site Visit (OSV) process that pushes FQHCs toward continual compliance and a more objective evaluation of your health center. It’s important for health center leaders to keep these things in mind when preparing for OSVs. Whether it’s contracting consultants to provide mock site surveys or utilizing web-based tools to guide your preparation, continual compliance should be the goal.

“1, 1, & Done”

HRSA implemented the so-called “1, 1, & Done” rule in January 1, 2019. According to the Compliance Manual, “an existing health center that fails to demonstrate compliance with all Health Center Program Requirements may only be awarded Federal Service Area Competition (SAC) funding for a one-year project/designation period.” After a grantee has received two back-to-back one-year project periods, “as a result of noncompliance with any Health Center Program requirements and review of a subsequent SAC application would result in a third consecutive one-year project period due to noncompliance with Program requirements, HRSA will not fund a third consecutive one-year project period.” HRSA states that a new service area competition may be announced at that time.

Continual Compliance

Health centers are expected to be 100% in compliance from the moment the documents are submitted for review. In prior years, reviewers were permitted to make changes while the survey team was onsite. Now, HRSA is no longer permitting those “quick fixes”. It is now even more critical for health centers to put in the effort to be continually-compliant.

Onsite Project Officers

A federal presence is always provided for Operational Site Visits. The assigned federal representative will participate in your initial pre-OSV conference call but may join the HRSA OSV virtually or in-person.

HRSA continues to provide assistance to health centers to ensure they are continuously compliant. A best practice is to develop a “Continuous Compliance Plan”. For more information, please read our blog post on this very topic: Developing a Continuous Compliance Policy and Plan.

Reviewed for Currency: August 8, 2024.