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Section: Spotlight Articles, September 2018
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Compliance Corner: HRSA Compliance Manual Updated

HRSA’s Bureau of Primary Health Care has revised the Health Center Program Compliance Manual, which was originally issued in August 2017, to reflect the amended Section 330 of the Public Health Service (PHS) Act (42 U.S.C. 254b). The Site Visit Protocol and other supporting documents have also been updated. The updated Site Visit Protocol will be used for all OSVs occurring after Thursday September 6, 2018. Below is a summary list of revisions that are important for you to know. A fully detailed list of revisions can be found here.
  • Chapter 2: Health Center Program Oversight
    • ​Revisions based on the new requirements that HRSA must award a one-year project period when HRSA finds that a health center has not demonstrated compliance with Health Center Program requirements, and for such health centers to submit an implementation plan for compliance within 120 days of award.
  • Chapter 3: Needs Assessment
    • ​Revisions to make requirement: “The health center must assess the unmet need for health services in the catchment or proposed catchment area of the center based on the population served, or proposed to be served, utilizing, but not limited to…”
  • Chapter 4: Required and Additional Health Services
    • ​Revisions to comply with the PHS Act that replace the term “substance abuse” with “substance use disorder.”
  • Chapter 9: Sliding Fee Discount Program
    • ​Revisions based on a technical correction of typographical error (deleting two commas) that produces a clearly erroneous statement (Demonstrating Compliance- k)
  • Chapter 11: Key Management Staff
    • Revisions based on amendments to the PHS Act that require the health center to directly employ the Project Director/Chief Executive Officer.  References to contracted PD/CEO have been removed. 
  • Chapter 12: Contracts and Subawards
    • Revisions based on amendments to PHS Act that require the health center to directly employ the Project Director/Chief Executive Officer.  References to contracted PD/CEO were replaced with phrases of “direct employment.”
  • Chapter 14: Collaborative Relationships
    • ​Revisions to reflect new requirements for health centers to establish and maintain collaborative relationships with other health care providers, local hospitals, and specialty providers to provide access to services not available through the health center and to reduce the non-urgent use of hospital emergency departments.
  • Chapter 15: Financial Management and Accounting Systems
    • Revisions to reflect new requirements for health center to have written policies and procedures to ensure the appropriate use of federal funds.  This requirement to safeguard federal assets is consistent with the existing Demonstrating Compliance Element (a) in this chapter, which requires health centers to demonstrate that they have written policies and procedures in place to ensure the appropriate use of federal funds in compliance with applicable federal statues, regulations, and the terms and conditions of the federal award.
  • Chapter 19: Board Authority
    • References to contracted PD/CEO removed consistent with the new requirement that health centers are to directly employ the PD/CEO.
  • Glossary
    • Revisions based on amendments to the PHS Act that include homeless veterans and veterans at risk of homelessness, as among the populations health centers receiving Section 330(h) funding may serve. 

Do you have questions about compliance or need more resources? Contact Cassandra McNulty, TPCA Compliance Manager, via email or at 615-425-5862.