In August 2017, HRSA finally published its long-awaited Health Center Program Compliance Manual. This new Manual clearly spells out Health Center Program Requirements, and, by doing so, replaces several Policy Information Notices (PINs) and Program Assistance Letters (PALs). The Manual explains why each Program Requirement is legally required, what a Health Center has to do to meet the requirement, and where a Health Center has flexibility in areas related to the requirement.
The information in this new Manual is designed to make it easier for Health Centers to stay compliant and should be very helpful as Health Centers prepare for future Operational Site Visits (OSVs). There is a second part to the Manual still to come - HRSA is planning on releasing a new Health Center Program Site Visit Guide soon based on the requirements spelled out in the Manual. The new Guide will be used during future OSVs, but the new Manual is in effect now.
What does this new Compliance Manual mean for Health Centers?
- OSV consultants now have less ‘wiggle room’ in interpreting HRSA requirements. The wording in the Manual is more exact and should reduce potential disagreements between Health Centers and OSV consultants.
- If something is not required by the Manual, it cannot be made into a requirement.
- OSV consultants will not be allowed to weigh in on areas where the Health Centers have been given flexibility. The consultants may have opinions on what they think would be ‘better’ in these areas, but if the Health Center has chosen a different option, that is the Health Center’s prerogative.
- HRSA recognizes that some OSV consultants have overstepped their boundaries or misinterpreted what was required of Health Centers. HRSA will closely review future OSV reports to make sure the Manual is being followed correctly.
If you want to read the new Manual (all 92 pages!), check it out at: https://bphc.hrsa.gov/programrequirements/pdf/healthcentercompliancemanual.pdf