#9 - When Should We Start?: A model for moving from episodic to continuous HRSA compliance

Our team receives one question more than any: “How soon should we begin preparing for a HRSA Operational Site Visit?”.

In my mind this is similar to asking, “How soon should we think about paying taxes?” Or, “How soon should we begin preparing for retirement?” The facts are that all of these things are guaranteed to happen. You will be required by Uncle Sam to pay taxes every year and so you pay a little with each paycheck so you’re not having to fork out a huge chunk of money in March. There will come a time when you are no longer able to work and so you pay a little in Social Security with each paycheck and put a little money away every month to build your retirement savings money. You can wait until later but there is a cost if this is done.

The same applies to HRSA OSVs. When your health center signed on the dotted line to receive funds from the government, one of the things you were agreeing to was a HRSA OSV at least every three years. You also attested and demonstrated that you would work to follow the numerous HRSA Program Requirements described in the HRSA Compliance Manual. And so, you and your health center team may not know the exact date the HRSA review team will be arriving, but you have a pretty high degree of certainty that it will happen roughly every three years. Not only that, but several years ago, HRSA began pushing all health centers toward what they call, “Continuous Compliance” …meaning that you are “survey-ready” every day.

Now this is a pretty big mindset change for most health center leadership teams. Most health centers will not think about their HRSA compliance until 6 months before their OSV. In our experience, this is already too late to begin to work toward HRSA compliance – the health center will pay for this delay in one or more ways. They will either pay for it in terms of hiring expensive consultants right before the OSV, paying for overtime of staff, the creation of a chaotic and stressful work environment, or will simply receive numerous findings of non-compliance at the time of the OSV (which then costs the health center in time, resources, and money to correct after the OSV as well). The point is, there is a heavy cost of episodic compliance. Our estimates show that this “cramming for the test” can cost an organization roughly $100,000-and that’s just the quantifiable part. The stress and chaos placed on an organization is less measurable but certainly palpable throughout the organization.

Just like taxes and retirement, there is a cost to planning ahead for the inevitable. But it is much more cost-effective to chip away month after month than get to tax time and not have the cash to pay taxes (which results in unnecessary stress and taking out high-interest loans or payment plans).

Our team’s collective experience has shown that striving toward a state of continuous HRSA compliance is not only what HRSA requires of us, but it also saves money, reduces stress and chaos, and ultimately results in more stable HRSA funding (less conditions placed on your grant). So, we have built our entire model around helping health centers move toward continuous HRSA compliance and we have developed a five-step plan for how health centers can do this:

Process for moving from episodic compliance to continuous compliance:

  1. Subscribe to RegLantern (At least 8 months prior to scheduled OSV)
  2. Load documents, set review dates, and complete forms in RegLantern (This usually takes most health centers 1-2 months on average)
  3. Review your compliance by enrolling in a RegLantern remote mock review (At least 6 months prior to scheduled OSV)
  4. Correct areas of non-compliance (You may need to update policies and contracts updated and approved by the Board so you need at least a few Board meeting where this can be done)
  5. Integrate a Continuous Compliance Process and Plan into your health center operations (We have a sample process and plan we provide to subscribers)

And so, in short, the answer I usually respond to the “how soon?” question is, “at least 8 months (at the very, very minimum) prior to your scheduled OSV”. But the health center should look at this as an exit off the bumpy “Episodic Compliance Road” and an on-ramp to the much smoother “Continuous HRSA Compliance Highway”. Then your team will be on-track to move toward continuous compliance after your HRSA OSV.

Having trouble moving toward HRSA continuous compliance? Contact our expert team at www.RegLantern.com. Our FQHC Mock Site Visits and web-based HRSA Continual Compliance tools will help save you time and money.