The Operational Site Visit or OSV is a critical part of HRSA’s Health Center Program to
assess and support a Federally Qualified Health Center’s compliance with the Health Center
Program’s requirements.
Hi!
I’m Angela Powell, Director of the Office of Southern Health Services.
Some important new changes to the guidelines are now in effect to align with the
Bipartisan Budget Act of 2018.
We’ve also made changes to ensure your OSV is a more streamlined and effective process.
We’ve received a lot of questions about the changes and just how they affect you.
I’m here to give you answers to the questions we heard most often.
Hmm. I've always wanted to try this...
Angela, my question is when can a health center expect that their OSV to take place?
Since project periods, or the designation period for Look-Alikes, are for either 1 or
3 years, an OSV will be scheduled based on the length of the project or designation period.
All new health centers and those with a 1-year project or designation period will receive
an OSV 2-4 months from the date the project or designation period begins.
Health centers currently in a 3-year period, will be scheduled for an OSV 14 to 18 months
from the date the project or designation period begins.
Okay, so who will be conducting the OSV given that the health center’s Project Officer
will no longer attend the OSV?
That’s right.
To support an objective review during OSVs, your HRSA Project Officer, or PO, no longer
serves as the onsite HRSA representative on your OSV.
In addition, your PO will NOT review the report nor help resolve any potential, preliminary
non-compliance findings from the OSV.
But your PO will still be available to serve as your initial contact during the prep stages
of the OSV, and will connect you with your onsite HRSA representative and consultant
team that will conduct your health center’s OSV.
Don’t worry, your assigned onsite HRSA representative will be briefed by your PO in advance of your
OSV to ensure that they come to the OSV with knowledge of your health center and your health
care environment.
To support the OSV process and provide program requirement guidance, a HRSA representative
will be assigned to participate before, during and after the visit.
So what happens if the OSV uncovers an area where a health center has a compliance finding?
Can the health center just try to fix it right then and there?
Our approach is to support all health centers being continually compliant with all program
requirements.
And, as of January 2019, health centers are no longer permitted to resolve non-compliance
findings for the Site Visit Report onsite DURING the OSV.
But we are excited to introduce a new process that provides health centers the opportunity
to resolve findings of non-compliance, BEFORE the OSV report is finalized.
It’s called the Compliance Resolution Opportunity or CRO.
Is the intent of the CRO to replace the onsite scramble to gather, or even create
materials DURING the OSV in an attempt to demonstrate compliance?
Exactly!
Now if your OSV results in findings of non-compliance, your health center will receive a task in
EHB, within 30 days following your OSV.
It will also contain a copy of the preliminary OSV report.
Your health center will have 14 calendar days from the issuance of the CRO EHB task to respond
to any preliminary OSV findings of non-compliance.
This specific EHB task will allow your health center to submit information to resolve any
non-compliance findings.
If your health center is able to demonstrate compliance by providing acceptable evidence
in response to the EHB task…
• The OSV report will be updated to note resolution of the non-compliance finding during
the process • The resolved Element will be marked as
compliant in the OSV report and, • No condition will be applied.
Should your health center choose not to respond to the CRO, or is unable to submit documentation
that demonstrates compliance within the 14 calendar day review period, conditions will
be added to your award for any UNRESOLVED non-compliant elements.
If there are non-compliant findings, will the project period be shortened right away?
No!
HRSA will NOT shorten a project/designation period as a result of OSV non-compliance findings.
OSVs occur in the middle of the project or designation period.
Project or designation period length determinations are made at the time of Service Area Competition
or Renewal of Designation awards.
Angela, one final question, where can our health centers find more information?
Please take advantage of our many online resources to help you prepare for your OSV.
You’ll find Site Visit Protocol and Compliance Manual materials on our website.
Be sure to also check out our short video on Five Tips for a Successful Site Visit.
Thank you for all you do to support our mission to improve health outcomes and address health
disparities through access to quality services, a skilled health workforce, and innovative,
high-value programs.