HRSA Operational Site Visit (OSV) Changes

AAFCPAs would like to make our Federally Qualified Health Center (FQHC) clients aware of recent updates issued by the Health Resource and Services Administration (HRSA) related to the Health Center Operational Site Visit Protocol.

HRSA summarized the updates in two categories: Substantial Updates & General Updates.

Substantial Updates

The two most significant substantial updates include site visit documentation consolidation and performance analysis.

1. Under the documentation consolidation updates, HRSA consolidated the two request lists for OSV documentation into one list. Previously there was one list for documents to be provided prior to the OSV and one provided at the start of the OSV.
2. The performance analysis requirement was removed entirely from the Site Visit Protocol “…in an effort to streamline OSVs and focus on compliance assessment.” The removal of this requirement should reduce the burden on administrative and clinical staff in preparing for and going through the OSV as FQHCs are no longer required to document and show measured progress and goals towards certain clinical outcomes.

General Updates

In the general updates section, AAFCPAs has outlined the following areas of significance:

1. The Site Visit Protocol has “clarified that health centers should provide samples representative of their current operations.”  AAFCPAs advises Health Centers to ensure that all policies and procedures are documented, up-to-date, and reflect current operations.  Personnel, systems, and processes are ever changing, especially in the pandemic environment, so HRSA has added additional emphasis on the importance of written, up-to-date policies and procedures.
2. The new protocol clarifies documentation requirements related to how testing and sampling will be conducted as it relates to required and additional health services and Form 5A: Services Provided. This clarification is meant to provide better guidance for OSV reviewers and provides consistency in OSVs.
3. The new protocol provides clarification of testing procedures over sliding fee discounts for services provided under columns II and III of Form 5A, and clarification as to how to document/ demonstrate certain nominal charges are in-fact nominal to certain income levels.
4. For contracts and conflict of interest requirements, the changes have instructed the reviewer to focus on contracts and sub-awards paid by the Federal 330 grant.  In addition, the review of contracts will consist of those that “utilize the highest amount of federal award funds.”
5. The new protocol provides a “revised methodology for Demonstrating Compliance Element (DCE) f. Timely and Accurate Third-Party Billing to include improved sampling and data for claims submissions and resubmissions.”
6. Health centers are required to provide an updated Form 6A if board compensation has changed since the last grant application to HRSA. In addition, health centers should ensure that their by-laws have up-to-date documentation on board member selection and removal. The updates also address how to evaluate patient representation of board members using the UDS and the Board member’s connection to the community. AAFCPAs advises clients to document how patient board members are representative of the individuals served by the health center, and how each patient board member qualifies as a patient board member, i.e. is receiving at least one visit at the health center, for an in-scope service, per year.

A complete list of the updated OSV protocols are available at: https://bphc.hrsa.gov/programrequirements/site-visit-protocol/summary-updates

AAFCPAs has been working with community Health Centers for over 30 years and can be of valuable assistance in developing and implementing the necessary changes. If you have questions about preparing for your HRSA OSV, operational manuals, or policy & procedure documents, please contact your AAFCPAs’ partner, or Charlie Webb, CPA at 774.512.4046, cwebb@aafcpa.com.