The simple answer is Yes!
HRSA requires health centers to have position descriptions for key personnel (also referred to as key management staff) who have the necessary experience and qualifications to carry out the activities of the health center. The health center has the discretion to determine the makeup of and distribution of functions among its key management staff, and the percentage of time dedicated to the health center program project for each position, as necessary to carry out the HRSA-approved scope of project. The health center also determines key management staff position titles (for example, utilizing the title “CEO” or “Project Director”) and how functions are distributed among its key management staff positions (for example, determining in a smaller health center whether it is appropriate to combine the CEO and CFO functions). Lastly, the health center determines when and if it is appropriate and necessary to contract for key management staff positions (other than the CEO, who may not be a contractor), rather than directly employ such individuals.
In healthcare, “good enough” compliance is a massive risk. Between shifting regulations and the manual headache of tracking every detail, it’s easy for things to slip through the cracks.
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