At the end of December, 2018, HRSA updated all consultants and reviewers about changes that went into effect as of January 1, 2019 and will impact all FQHCs.
“1, 1, & Done”
As we’ve heard for several months now, effective January 1, the so-called “1, 1, & Done” rule went into effect. According to the Compliance Manual, “an existing health center that fails to demonstrate compliance with all Health Center Program Requirements may only be awarded Federal Service Area Competition (SAC) funding for a one-year project/designation period.” After a grantee has received two back-to-back one-year project periods, “as a result of noncompliance with any Health Center Program requirements and review of a subsequent SAC application would result in a third consecutive one-year project period due to noncompliance with Program requirements, HRSA will not fund a third consecutive one-year project period.” HRSA states that a new service area competition may be announced at that time.
No More “Quick Fixes”
Until now, Operational Site Visit (OSV) reviewers and Project Officers were given the leeway to provide “Quick Fixes” for minor areas of non-compliance. For example, if an area on Form 5A (Required and Additional Services) was incorrect, or if a policy just needed a few words changed, reviewers would often allow the health center to quickly fix the document to get it back in compliance if they could do it before they were wrapping up their visit. As of January 1, 2019, this will no longer permitted. Health centers are expected to be 100% in compliance from the moment the documents are submitted for review. Reviewers have commonly used this allowance for a number of areas of compliance so it is now even more critical for health centers to put in the effort to be continually-compliant.
No More Assigned Project Officers Onsite
In an effort to ensure OSVs are carried out with the greatest amount of objectivity, effective January 1, 2019, HRSA has announced that the health center’s assigned Project Officer (PO) will no longer be onsite for the OSV. A federal presence will still be provided but the Project Officer will not be the individual assigned to your health center. Your assigned PO will participate in your initial pre-OSV conference call but will then handoff the ongoing OSV duties to the other PO who will be participating in your onsite experience. Since you likely have a close relationship with your assigned PO and they are very familiar with your operations, you will need to make sure you speak with them long before your next OSV to ensure they are able to relay anything of importance to the PO who will be onsite during your OSV.
Site Visit Protocol Updates
HRSA announced that some minor changes will be made to the HRSA Site Visit Protocol in April, 2019. Keep an eye out for these changes, especially if you have an OSV in the Spring or Summer of 2019.
If you are a subscriber to our RegLantern platform, you can be assured that as soon as those updates are released, our team at RegLantern will immediately work to update our tools to keep you continually compliant and up-to-date with the very latest changes in HRSA Program Requirements.
If you are interested in any of our health center compliance tools and services, please visit us at https://reglantern.com/. Have a great start to your New Year and hope this information helps light the way to health center excellence!
You can view a video post about these changes at https://youtu.be/sxhVBp5nTcs.