As a general rule of practice, all governing board actions and communications require the board chair and/or board secretary signature as official documentation regarding board discussion and approval. The approval of all health center policies is required as part of the board’s authority. Therefore, any OSV non-compliance findings that include policy revisions must be approved by the board and signed by the board chair. Lastly, it is important to understand that the contractual relationship that allows an organization to become a part of the health center program, exists between HRSA/BPHC and the health center’s governing board. Hence, while the CEO’s signature can be included in revised policies, the board chair’s signature is a requirement.
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.