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Category: Ask an Expert

Fitness for Duty

Can you please explain what is required to demonstrate compliance with Fitness for Duty?

HRSA Patient Visit Billing Expectations

There are many different factors that could impact HRSA’s expectations for billing patient visits. Could you help us make sure our billing procedures are in alignment with their guidelines?

LIPs vs OLCPs

We are in the process of revising our Credentialing and Privileging Policy and Procedures. Can you please clarify the difference between Licensed Independent Practitioners (LIPs) and Other Licensed and Certified Practitioners (OLCPs)?

Interim CEO: 1099 or W2?

We currently have an Interim CEO and didn’t know whether the individual can just be a 1099 contractor instead of a W-2 employee because they are not permanent.

Patient Samples for Chapter 8

We are in the process of preparing patient samples for our upcoming Virtual Operational Site Visit (VOSV), can you please tell me what we will need to show for the samples required for “Chapter 8 – Continuity of Care?”

Naming Convention for Documents for OSV

Can you clarify naming conventions for the multiple documents in multiple places for OSV? My understanding was that, though documents are needed in more than one place, they can be named the same.

Financial Accounting System Requirement

HRSA requires that the health center can track expenditures of the Health Center Program project funds. We currently use an Excel Spreadsheet along with a fiscal system. Is this ok?

Pharmacist Category of Staff

Is a Pharmacist credentialed and privileged as a Licensed Independent Practitioner (LIP) or Other Licensed and Certified Practitioner (OLCP)?

Compliance in Action

June 23rd, 2026

10:00 AM PT // 1:00 PM ET

Evidence-Based Strategies for Demonstrating Program Effectiveness

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.