Updating Bylaws Based on HRSA Site Visit Protocol Changes

On Friday, January 31, 2025, HRSA Site Visit Protocol Chapter 12 (Contracts and Subawards) and 20 (Board Composition), as well as the PDF version of the HRSA Site Visit Protocol, were noted to have been removed from the HRSA Site Visit Protocol page. Though it was not confirmed at the time, it was believed that the language that prompted this removal was related to the word “gender” that is in both of these chapters, requiring the health center to “provide documentation demonstrating that health center and subrecipient boards’ demographics are representative of the health center’s/subrecipient’s “patient population in terms of race, ethnicity, and gender consistent with the demographics reported in the health center’s UDS report.” The UDS Data for all health centers was also noted to be removed from Data.HRSA.gov. It was believed that both of those chapters were temporarily removed due to the Executive Order directing all agencies to “use the term ‘sex’ and not ‘gender’ in all applicable Federal policies and documents”.

On Saturday, March 15, 2025, it was noted that Chapter 20 (Board Composition) was returned to the Site Visit Protocol website. Upon review, as anticipated, the words “gender” were replaced with “sex”.

The two areas that were altered were questions 4.3 and 9 in Chapter 20 of the Site Visit Protocol:

4.3. Do the bylaws or other corporate or governing documentation include provisions that ensure: Patient members of the board, as a group, represent the individuals who are served by the health center in terms of demographic factors, such as race, ethnicity, and sex [formerly “gender”]?

9. Are patient board members as a group representative of the health center’s patient population in terms of race, ethnicity, and sex [formerly “gender”] consistent with the demographics reported in the health center’s UDS report?

On Friday, March 21, 2025, it was noted that Chapter 12 (Contracts and Subawards) was returned to the Site Visit Protocol website. Upon review, as anticipated, the words “gender” were replaced with “sex”.

The one area that was altered was question 20.4 in Chapter 12 (Contracts and Subawards) of the HRSA Site Visit Protocol:

20.4. Did the health center provide documentation demonstrating that each subrecipient is currently compliant with the following Board Composition requirements: Patient board members as a group are representative of the subrecipient’s patient population in terms of race, ethnicity, and sex [formerly “gender”] consistent with the demographics reported in the health center’s UDS report?

It is recommended that health centers review their bylaws or other corporate or governing documentation and consider changing any language around “gender” to align with the changes in the HRSA Site Visit Protocol, replacing the word “gender” with “sex”.

UPDATED: March 21, 2025 with Chapter 12 updates.

UPDATED: March 22, 2025 (Chapter 12 was again removed from the HRSA SVP website).

UPDATED: March 25, 2025 (Chapter 12 was returned to the HRSA SVP website).