We are having a Virtual Operational Site Visit (VOSV) in May of this year. Are we allowed to provide the VOSV team with a recording of the tour?
The simple answer is no. As outlined by the additional guidance provided by the Health Resources and Services Administration (HRSA) titled, “Supplement to the Health Center Program Site Visit Protocol: Guidelines and Logistics for Virtual Operational Site Visits” (June 30, 2020), the health center will conduct a LIVE virtual tour for the VOSV team utilizing video conferencing software and the health center’s equipment, such as a phone, tablet, or computer camera. The health center is NOT permitted to utilize a pre-recorded tour or a picture slideshow to meet the requirements of the virtual tour. The supplemental guidance referenced above will be provided to the health center as a document in the Citrix ShareFile System, once access is granted.
The tour is conducted much like an “in-person” tour and will originate outside the building and progress through the interior. If the health center has multiple sites, at least two sites will be toured. It is at the discretion of the health center to determine which sites will be toured, although the health center should include at least one site where the majority of in-scope services are provided.
The health center should prepare for the tour(s) in advance. The following are tips for a successful VOSV tour:
Health centers should utilize the guidance provided in the HRSA Health Center Compliance Manual (Health Center Program Compliance Manual) to prepare for their VOSV. Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in HRSA Site Visit Protocol (Health Center Program Site Visit Protocol).
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.