With the implementation of Virtual Operational Site Visits (VOSVs), many health centers are questioning whether the requirements for maintaining compliance have changed.  The simple answer is “no”.  Although the logistics for conducting the visit have changed, health centers are still expected to meet the compliance expectations outlined in the Health Resources and Services Administration (HRSA) Health Center Compliance Manual (HRSA Compliance Manual), and the review continues to be conducted utilizing the HRSA Health Center Program Site Visit Protocol (HRSA Site Visit Protocol).

As with onsite OSVs, the Clinical Reviewer is expected to place a “test call” to the after-hours line, during the VOSV, to validate the system ensures access to care for patients after normal business hours.  The call is placed at some point during the scheduled VOSV outside of normal business hours and should NOT be placed prior to the official start of the VOSV.  In the event the call is placed prior to the start of the VOSV, the health center should notify the Federal Representative assigned to the visit.  

Although the Clinical Reviewer has the option to present themself as a “fake patient,” this method of testing can pose challenges for “test calls”, as the answering service, nurse triage service and/or on-call provider will not be able to locate the patient in the Electronic Health Record (EHR). For this reason, most Clinical Reviewers identify who they are and why they are placing a “test call”.

To validate compliance, the Clinical Reviewer must place a “test call” to the after-hours line and receive a return call that verifies the following:

• Connection to an individual with the qualifications and training necessary to exercise professional judgement to address an after-hours call.
• Connection to an individual who can refer patients to either a licensed independent practitioner for further consultation, or to locations such as emergency rooms or urgent care facilities for further assessment or immediate care as needed.
• Provisions are in place for calls received from patients with Limited English Proficiency (LEP), such as translation services. 

Health centers should follow the guidance outlined in Chapter Seven of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 7).  Additionally, health centers can conduct a self-evaluation of compliance with all the requirements for this chapter by answering the questions in the “Coverage for Medical Emergencies During and After Hours” section of the HRSA Site Visit Protocol (Site Visit Protocol Coverage for Medical Emergencies After Hours).