Handling Key Vacancies During an OSV

Due to time and unforeseen occurrences, having a key vacancy within a health center can happen at any moment; but it may be especially difficult during an operational site visit. It is important to know that a “key” position is identified by the health center as described in Chapter 11- Key Management Staff. If your health center is having a site visit and there is an identified key vacancy, it is important to complete the following:

  1. Notify the HRSA Review Team and Federal Representative. By notifying the review team, it will help to determine whether changes to the site visit agenda may need to be made. For example, if the Medical Director position is a vacant position, the Clinical Reviewer may need to interview another individual identified as the interim Medical Director.
  2. It is important to remember that site visits are a point in time visit, and vacancies can and do occur. If you have a vacancy (or vacancies), remember to review Element C (Process for Filling Key Management Vacancies).  The Health Center Program Site Visit Protocol identifies the documents that need to be provided if a vacancy is identified. Documents include, but are not limited, to Human Resources procedures relevant to recruitment and hiring of key management staff and documentation associated with filling the vacancy. A health center can have a key vacancy and be in the process of recruiting for that position. If this is the case, the health center should discuss the plan for filling that position or, if it’s in process, the current status of the implementation plan. 

Regardless of the vacancy, it is important to be open and honest as having a key vacancy does not necessarily result in an element being non-compliant. Health Centers can perform a self-evaluation of compliance by answering the questions in the HRSA Health Center Site Visit Protocol, Chapter 9-Key Management Staff, as well as reviewing the Health Center Program Compliance Manual.

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