Ask an Expert: How does our participation as a contractor with a community partner affect our OSV?

How would our participation as a contractor with a community partner (City or County) affect our Operational Site Visit review? What potential chapters might be affected if we are testing community members who might not be our patients?

Hi! Thank you so much for your question. From how I read your question it sounds like your community health center model may be a Public Entity, Co-Applicant Model where the “grantee of record” is the County/City and the co-applicant is the community health center. I’m not really sure, but will try to provide an answer that will be helpful (and please feel free to reach out directly in case I didn’t interpret your question correctly) 🙂 


In the Public Entity Co-Applicant Model, the governing board of the Community Health Center (CHC) has to meet the Program Requirements required by HRSA, as stated in the Compliance Manual (Board Authority & Board Composition). Please find the link here: This would include that 51% of the governing board are patients of the health center. Those that are patients must as a group represent the individuals served by the health center in terms of race, ethnicity and gender. The remainder of the board are representatives (non-patient board members) and come from the community and have various forms of expertise. Non-patient board members can’t derive more than 10% of their annual income from the healthcare industry. Remember, the Community Health Center (NOT HRSA) defines what “healthcare industry” means, so remember to document that in a policy or your governing bylaws.  From an Operational Site Visit Review, the Operational Site Visit Protocol focuses on Chapter 19 Board Authority & Chapter 20 Board Composition. More information on what is required for the board can be found here:


Choosing non-patient board members requires thoughtful consideration and should be based on the needs of the organization. HRSA does not have any specific requirements as to what type of non-patient board members are selected, BUT does provide characteristic examples of non-patient board members.These can be found in the Operational Site Visit Protocol, Chapter 20, Board Composition, Element B or here: . A best practice would be to create a board matrix which helps to keep track of board characteristics and when a need arises, a board matrix can help identify what area of expertise is needed. 

More information on Public Entity Co-Applicant Health Centers can be found here: .  We hope this helps and we have answered your question. Please feel free to reach out again!

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