We currently have an Interim CEO and didn’t know whether the individual can just be a 1099 contractor instead of a W-2 employee because they are not permanent.
The Health Center Program Compliance Manual and its companion, the Health Center Program Site Visit Protocol, provide guidance that the CEO must be directly employed by the health center as confirmed by a W-2 (Chapter 11-Key Management Staff, Element D, Question #4) and cannot be a 1099 contractor regardless of if they are an Interim CEO. The Project Director/CEO is directly employed by the health center if the Project Director/CEO: (1) receives a salary directly from the health center; (2) is issued a W-2 that lists only the health center as the Project Director/CEO’s employer; and (3) has an employment agreement entered into with the health center that outlines the activities required to be performed by the Project Director/CEO. For health centers that are considered a public agency, co-applicant board, the CEO/Project Director may report both to the co-applicant board and to another board or individual within the public agency. For individual questions, please check with your HRSA Project Officer and to read more, please review this link:
https://bphc.hrsa.gov/programrequirements/site-visit-protocol/key-management-staff
May 28th, 2026
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