Ensuring Board Members are Compliant with the HRSA Patient Requirements

As community health centers are governed by a board of directors, the board of directors also must meet certain requirements; not only providing oversight but in the composition of the board. Chapter 20 (Board Composition) of the Health Center Program Compliance Manual outlines specific composition requirements  and this article will focus specifically on the patient board requirements. In order to meet compliance, at least 51% of the governing board must be patients of the health center. For the purposes of this requirement, a patient is an individual who has received at least one service in the past 24 months that generated a health center visit, where both the service and the site where the service was received are within the HRSA approved scope of project.  A legal guardian of a patient who is a dependent child or adult, a person who has legal authority to make health care decisions on behalf of a patient, or a legal sponsor of an immigrant patient may also be considered a patient of the health center for purposes of board representation. Ensuring that board members understand and fulfill their obligations is essential to continuous compliance. Health Center leadership can assist board members in being compliant with this specific requirement by:

  • Providing education to board members. Providing comprehensive training should include the importance of the HRSA program requirements, and the meaning behind the requirement. Being a patient majority board brings expertise and experiences to the development of the health center policies that impact the health center patient population. 
  • Keeping track of documentation in meeting the patient requirement. Assigning someone to keep track of the 51% patient requirement can be completed by monitoring billing records or the date of a visit in order to limit this being in a patient’s health record. It is important to remember that patient board members are afforded the same HIPAA protections as other patients.
  • Fostering ongoing communication and support. Having open communication between board members and key management can help to address any questions or concerns related to the HRSA program requirements. One way to complete this is to provide ongoing or annual board of directors education.


Keeping board members knowledgeable of the program requirements and the meaning behind the requirements will assist board members with their appropriate oversight and responsibility.  

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