As described in Chapter 11-Key Management Staff in the Health Center Program Compliance Manual, HRSA requires the Project Director/CEO position to be directly employed by the health center and report to the governing board. As transitions in health centers occur, the Project Director/CEO position must be directly employed and not be a contractor. A health center can have an Interim Project Director/CEO, but that individual must be a W-2 employee. During an Operational Site Visit (OSV), a health center can demonstrate compliance by presenting one of the following:
The health center determines which document to provide during the OSV.
Regulators are no longer satisfied with documentation alone; they want evidence that your compliance program actively prevents, detects, and corrects risk. Investigators expect to see how issues are identified early, investigated thoroughly, corrected effectively, and monitored over time. Boards demand measurable insight, and leadership needs confidence that exposure is managed before it becomes a liability. The standard has shifted from activity to impact.