Articles 3 min read

Preparing for Your HRSA Operational Site Visit: A Readiness Checklist

Key Takeaways

The OSV is not a financial statement audit. A multidisciplinary HRSA team assesses compliance with the Health Center Program requirements behind your Section 330 funding.

Most findings come from documentation that cannot be produced quickly and consistently upon request. Readiness is built year-round through assigned ownership, current policies, and documented reconciliations.

When the notice arrives, confirm prior conditions are closed and evidenced, run a mock visit, and prepare the people who will be interviewed.

For a Federally Qualified Health Center, the HRSA Operational Site Visit (OSV) is one of the most consequential compliance reviews in the grant cycle. Unlike a financial statement audit, the OSV evaluates whether the organization complies with the Health Center Program requirements that support its Section 330 funding. HRSA generally conducts an OSV once each period of performance, and the process includes an advance documentation review and interviews with leadership, clinical staff and board members.

The notice period is too short to build a record from nothing. Preparation is about showing, on request, that the processes behind the documents work.

What Does a HRSA Operational Site Visit Cover?

The Site Visit Protocol organizes a review around four areas: Need, Services, Management and Finance and Governance. Reviewers test whether each requirement is met in practice, not only whether a policy exists. Several areas tend to drive significant documentation and interview preparation, including:

A patient-majority board (at least 51% of members are patients), 9 to 25 members, monthly meetings with minutes, and documented authority over the budget, CEO selection, and strategic direction.

Accounting and internal control systems consistent with applicable GAAP/GASB principles, current billing and collections policies, a board-approved budget, and a completed Single Audit when federal expenditures meet or exceed the applicable threshold, currently $1 million.

Sites, services, providers, and service delivery methods that match approved Forms 5A, 5B, and 5C, with changes appropriately approved before implementation.

A board-approved Sliding Fee Discount Program policy and current schedules that apply uniformly to all patients, use the most recent Federal Poverty Guidelines (“FPG”), assess eligibility based only on income and family size, provide a full discount or nominal charge at or below 100% of FPG, provide graduated partial discounts above 100% and at or below 200% of FPG, and provide no discount above 200% of FPG unless supported by another permissible funding source.

How Should a Health Center Prepare Year-Round?

Work through the following before notice arrives:

  1. Assign an owner to each requirement so nothing falls between departments.
  2. Re-approve key policies on a set cycle, especially the sliding fee schedule, and confirm minutes capture what was approved, not only that a vote occurred.
  3. Reconcile your most recent UDS report to your audited financial statements each year, documenting any differences while fresh.
  4. Centralize the materials reviewers always request, labeled as the protocol asks, so assembling a submission becomes retrieval.

Withum’s Federally Qualified Health Center Services Team maintains a detailed OSV Readiness Checklist covering each requirement by protocol area, with owner, due date, and status tracking. Contact us to walk through it with your team.

What Should You Do When the Site Visit Notice Arrives?

The first step is to start with the prior review and confirm that every condition from the last visit is closed and evidenced. A finding that is corrected informally but never documented is still at risk. Next, run a mock site visit that should test consistency between the written policy, the support uploaded and what staff and board members say in interviews. If those three do not tell the same story, the document may exist, but the process may still appear underdeveloped.

What Does a Successful OSV Come Down To?

For a quick read on where you stand, pick five items from the protocol at random and ask your team to produce the support by the end of the day. What comes back quickly and accurately is likely in good shape. However, responses that take a week of searching identify a readiness gap and may lead to a finding.

Preparing for an OSV requires more than a last-minute review of documents. Unlike a financial statement audit, the OSV includes a multidisciplinary HRSA team that assesses compliance with the Health Center Program requirements behind your Section 330 funding. Since most findings come from documentation that cannot be produced quickly and upon request, it is crucial for organizations to maintain continuous year-round readiness through assigned ownership, up-to-date policies and documented reconciliations. By addressing prior conditions, conducting a mock visit, and preparing team members for interviews, Health Centers can approach an OSV with confidence and demonstrate ongoing compliance.

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Contact Us

For help assessing where you stand, support running a mock site visit or to learn more about organizing your preparation efforts for a HRSA operational site visit, contact Withum’s Federally Qualified Health Centers Services Team.

Let’s Chat

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