HRSA Sampling Review Resource Guide

FQHC Operational Site Visits (OSVs) require health center staff to demonstrate continual HRSA compliance by providing sample documentation of contracts and referral arrangements, provider personnel credentialing and privileging files, HRSA Forms 5A, 5B, 5C, and 6A, patient medical records, reports, and fiscal and billing records. This documentation allows HRSA reviewers to evaluate your health center’s compliance when compared with the Bureau of Primary Health Care’s (BPHC’s) Site Visit Protocol and Compliance Manual.

HRSA reviewers have some leeway as to how they select the documentation they wish to review. Additionally, there are some areas in the HRSA Site Visit Protocol in which health centers have some flexibility in deciding which samples to provide to the HRSA site visit team. In July, 2020, HRSA released the Health Center Program Site Visit Protocol: Sampling Review Resource Guide. This guide was meant to provide clarification on what is expected of health centers and how this documentation should be presented to HRSA review teams.

This resource covers required samples noted in the following HRSA Site Visit Protocol Sections:

  • Contracts/Referral Arrangements

    • Required and Additional Health Services

    • Clinical Staffing

    • Sliding Fee Discount Program

    • Contracts and Subawards

    • Conflict of Interest

  • Provider Files

    • Clinical Staffing

  • Patient Medical Records

    • Required and Additional Health Services

    • Coverage for Medical Emergencies During and After Hours

    • Continuity of Care and Hospital Admitting

    • Quality Improvement/Assurance

    • Eligibility Requirements for Look-Alike Initial Designation Applicants

  • Reports

    • Quality Improvement/Assurance

    • Contracts and Subawards

    • Financial Management and Accounting Systems

    • Program Monitoring and Data Reporting Systems

    • Board Authority

  • Fiscal and Billing Records

    • Sliding Fee Discount Program

    • Financial Management and Accounting Systems

    • Billing and Collections

Though much of this information can already be found in the HRSA Site Visit Protocol, this resource brings all of the key sampling information into one location. We recommend you utilize this document as you prepare for mock or HRSA Operational Site Visits and work toward continual compliance.

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Kyle Vath

Kyle Vath, BSN, MHA, RN: Kyle Vath is the CEO and co-founder of RegLantern, a company that provides tools and services to health centers that help them move to continual compliance. These services include mock site surveys and web-based tools that allow health centers to organize their compliance documentation. Kyle has served in a wide range of healthcare settings including serving as the Director of Operations for Social Ministries for a large health system, Provider Relations for a health system-owned payer, the Director of Operations for a Federally-Qualified Health Center, long-term care (as a nursing manager, director of nursing, and licensed nursing home administrator), in acute care (as a critical care nurse), and in Tanzania, East Africa as a hospital administrator of a rural mission hospital.

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