No. In review of Chapter 11: Key Management Staff, both the Compliance Manual and updated Site Visit Protocol require that the CEO/Project Director for the health center must be directly employed by the health center.  Demonstrating how the CEO/Project Director is directly employed is up to the health center. An employment agreement is just one method of documentation to demonstrate compliance. Other methods include a W-2 form, paystub, or other type of documentation showing direct employment by the health center. 

Having an employment agreement is dependent on several factors, including each state’s employment laws. Determining whether a CEO should have an employment agreement is not a HRSA Program Requirement. 

Remember, if health centers are part of a public agency using the co-applicant structure, compliance with Element D (Question #4) would be demonstrated by ensuring that the CEO/Project Director is directly employed by the Health Center awardee/designee of record. Additional information on this model of care and how to demonstrate compliance can be found at: https://bphc.hrsa.gov/compliance/compliance-manual/chapter11 and https://bphc.hrsa.gov/compliance/site-visits/site-visit-protocol/key-management-staff (refer to Footnotes).