Health Center Program Resources Update
Saturday, February 15, 2014
Posted by: Joy Ingram
by Krista Chuscavage, Member Services Coordinator
In January, I attended NACHC’s New Access Point training in Seattle
for Region IX & X newly funded health centers. Not only did I learn
a great amount about the benefits and requirements of being funded by
the Health Center Program, I also had the opportunity to hear our newly
funded health centers express their top concerns going forward as
first-time grantees. Many of these issues are relevant, and no doubt
have always been, for even the most established health centers. Some of
the topics identified have been recently addressed by the Bureau of
Primary Health Care (BPHC) or have been noted as current priorities.
These resources could not have come at a more pertinent time for all the new health centers. On the February 4th all programs quarterly webcast,
BPHC announced that 2014 will see funding opportunities for roughly
$300 million for expanded services and/or New Access Points. This is in
addition to the $150 million already awarded to 236 New Access Points
in November 2013.
New health center grantees specified governance requirements as a top concern. As you will see on our Resouces page, BPHC has released its FINAL
Policy Information Notice (PIN) 2014-1 Health Center Program
Governance. This PIN clarified some long-standing concerns regarding
health center governance in regards to board composition, bylaws
requirements, the role of the Executive Committee, board requirements
for public centers under co-applicant arrangements, and waiver of
governance requirements requests. Some of the questions answered in the PIN were these:
- What is a health center patient?
Health center patient board members must be current registered
patients of the health center and must have accessed the health center
in the past 24 months to receive at least one or more in-scope service(s)
that generated the visit. A visit is defined as a documented,
face-to-face contact between a patient and a provider who exercises
independent professional judgment in the provision of services to the
- What is needed in terms of non-patient board members?
The non-patient board members must be representatives of the
community currently served. A board must be comprised of members with a
broad range of skills, expertise, and perspectives. No more than one
half (50%) of the non-patient board members may derive more than 10% of
their annual income from the healthcare industry.
- What is required for special population patient representation?
Health centers that receive funding/designation under multiple
section 330 subparts must have patient representation on the board from
the populations targeted and served by the health center. At a minimum,
there must be at least one board member representing each of the
special populations for which the health center receives funding.
- What is an advocate of a special population?
Inclusion of advocates who have personally experienced being members
of, represent, have expertise in, or work closely with the special
population, however, would meet the requirement for
multi-funded/designated health centers to have representation of all the
populations for which the health center receives funding/designation. These
advocates would not be included in calculating whether the governing
board met the patient-majority requirement unless they were also health
center patients. Additionally, while advocates may represent special
populations on the board as outlined above, health centers should
continue efforts to recruit patient board members from the targeted
- How does the PIN address waivers for governance requirements?
This PIN eliminates waiver requests for any governance requirement other than for the fifty-one percent patient majority governance requirement for eligible health centers. In the past HRSA has allowed health centers to request waivers of the requirement for monthly board meetings. HRSA will no longer allow waivers for the monthly board meeting requirement,
given the improved uses of telecommunications and other information
technology to overcome previous geographic barriers to monthly
meetings. Existing waivers of statutory or regulatory health center
governance requirements beyond the 51 percent patient majority
governance requirement, including those granted under the authority of
section 330(e)(1)(B), expire consistent with the effective date of the
Operation Site Visits
Another major concern the newly funded health centers identified was Operational Site Visits (OSVs). On the Feb 4th
BPHC all-programs webcast, BPHC noted they are planning close to 500
site visits in 2014 compared to the near 400 site visits completed in
BPHC has released The Health Center Program Site Visit Guide. The
guide is the standardized review instrument used to conduct Operational
Site Visits. It includes review questions used by the team conducting
the site visit to assess compliance with each program requirement, as
well as to review progress on clinical and financial performance and
capital grants (if applicable), and, when possible, to identify any best
practices established by the health center. Health centers also may use
this guide to assess compliance with program requirements and to
identify clinical and financial performance improvement areas.
Updates to the OSV guide process include:
- Questions for assessing and documenting compliance have been
clarified and streamlined for all program requirements. In addition,
questions for the governance requirements have been updated to align
with the 2014 Health Center Program Governance Policy Information Notice.
- Performance improvement questions have been removed from all program requirement sections. Consultants will focus on performance improvement in the areas of clinical and financial performance.
- Documents which consultants are expected to review onsite or in
advance have been separated from general HRSA resources, such as Policy
Information Notices and Program Assistance Letters (PINs and PALs),
which are provided as background for each program requirement.
- The review of clinical and financial performance is now a separate section of the Site Visit Guide.
- Instructions and questions for assessing and documenting progress
and performance on the clinical and financial measures have been
clarified and streamlined.
- A new section and guidance has been added regarding
documenting Innovative/Best Practices to align with the standardized
site visit report format for Operational Site Visits.
- Appendix B: Optional Program Requirement/Performance Improvement
Summary Grid and Appendix C: Health Center Performance Measures have
been removed from the Site Visit Guide
BPHC may have a technical assistance call for the OSV Guide in the future. Watch the BPHC website for the announcement.
Additional guidance coming soon
Watch for an announcement on the following:
- FINAL PIN on Sliding Fee Discount Program (Spring 2014)
- FINAL PIN on Revised Total Budgets from BPHC
- BPHC will be releasing a Program Requirements Manual to better
clarify what health centers must do to comply with the 19 program
requirements and what documentation is required for showing compliance.
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