What is the best way to handle a situation where the health center does not agree with an area of non-compliance identified by the review team?
Operational Site Visits (OSVs) can be a stressful period of time for health centers. When conducting an OSV, the review team considers all the documentation provided by the health center, patient samples and information collected during staff interviews. The review team is responsible for utilizing the Health Resources and Services Administration (HRSA) Compliance Manual (Health Center Program Compliance Manual) to evaluate compliance and document any findings as directed by the HRSA Site Visit Protocol (Health Center Program Site Visit Protocol). In the event the health center does not agree with a finding identified by the review team, the health center should consider the following:
It is important to remember that findings identified by the review team and presented at the Exit Conference are strictly preliminary. All findings are reviewed by HRSA, and HRSA is responsible for making final compliance determinations.
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.