The Naming Convention: Consideration, not Compliance

During official notice emails and kick off calls for OSVs, Health Centers are given documents with extensive Naming Conventions and different versions. What does this mean? How do I handle them having different numbers?

Tow-MAY-tow. Tow-MAH-tow.

They are the same thing. You are compliant either way. But to be considerate of certain listeners, you should talk about the delicious summer fruit (or is it vegetable?) one way or the other. That is a “convention”.

Conventions are helpful to facilitate communication and organization so we can spend our lives doing more important things. The Naming Convention that HRSA requests through the Operational Site Visit (OSV) process helps reviewers find the documents they are looking for more efficiently. They also help reviewers know what purpose you intend a particular document to fulfill.

As we have helped dozens of subscribers through this process, we have a few insights regarding the Naming Convention:

1. RegLantern has you covered! For subscribers of RegLantern, we have built in a naming convention system that will append the HRSA required naming convention in front of your document name. So, when you upload a document or attach it to a particular prompt, you have an easy way to accept or update the naming convention. See the RegLantern help article here for a video tutorial.

2. The Naming Convention is a consideration but not compliance. There is nowhere in the HRSA Compliance Manual that requires you to name documents a certain way. There is no question in the Site Visit Protocol that asks, “Does the Health Center name Needs Assessments 3.2 – Recent NA?” That’s because this is not compliance. This is a way for you to be considerate of your reviewers and help them find what they’re looking for.

3. Don’t expect the numbering to make perfect sense. For the most part the numbering is in order and helpful for sorting. But when documents are repeated across chapters they are not always consistently borrowing from another chapter or creating new conventions. Don’t worry, RegLantern can handle different names for different chapters for the same document.

4. Remember these small things:

   1. For documents in two places, use both numbers – RegLantern can handle each situation: for example, 3.2 Map of Service Area and 6.1 – Map of Service Area.

   2. To keep track yourself – RegLantern keeps your document name so you can find it later.

   3. Try to upload all documents in PDF to help reviewers be able to access your files.

5. Check the version of the HRSA Naming Convention document. We have had numerous health centers reach out to us after their Project Officer gave them older, 2020 and 2021 versions that led to significant confusion (or most recent revision is from April 2023). Also, an important note: we do not know of any online version of the HRSA Naming Convention document in existence. In our experience, we are only seeing multiple PDF documents that are being passed around by HRSA Project Officers and not all of them are the most up-to-date versions. Obviously, this leads to a great deal of confusion.

As for the actual name of the document, HRSA provided some guidance here:

“…the name or title of a document may differ from that specified in the Site Visit Protocol. Health centers have discretion in how they name or title their documentation. The HRSA site visit team reviews documents to assess compliance with the program requirements. Compliance determinations are based on document content.

For example: Where the SVP asks the health center to provide a "board-approved policy," HRSA would assess compliance based on evidence of board approval and on the content of the document, regardless of whether the health center calls the document a "procedure" or "protocol" instead of a "policy."

Many demonstrating compliance elements allow for the review of "other documentation" to demonstrate compliance if health centers cannot demonstrate compliance in documents specifically listed in the SVP.

Certain terminology also may vary as long as it meets the intent of the demonstrating compliance element. For example, board meeting minutes may note that the board "accepted" a policy, and HRSA considers that terminology as equivalent to the board "approving" the policy.”

At the end of the day, well-organized, clearly named documents help you demonstrate your compliance and help reduce the confusion the reviewers feel. Be considerate of them, and they will be appreciative.

UPDATED: 11/22/2023 with updated document naming recommendations.