The short answer is No! For IHS-funded health centers during the Operational Site Visit, Chapter 17- Board Authority is not applicable. Per the HRSA Health Center Program Site Visit Protocol, “The governing board of a health center operated by Indian tribes, tribal groups, or Indian organizations under the Indian Self-Determination Act or Urban Indian Organizations under the Indian Health Care Improvement Act is exempt from the specific board authority requirements discussed in [Health Center Program Compliance Manual Chapter 19: Board Authority]. Section 330(k)(3)(H) of the PHS Act.”

Similarly, Chapter 18 – Board Composition is also not applicable. Per the HRSA Health Center Program Site Visit Protocol, “The governing board of a health center operated by Indian tribes, tribal groups, or Indian organizations under the Indian Self-Determination Act or Urban Indian Organizations under the Indian Health Care Improvement Act is exempt from the specific board composition requirements discussed in [Health Center Program Compliance Manual Chapter 20: Board Composition]. Section 330(k)(3)(H) of the PHS Act.”

The IHS Urban Indian Health Program does state the following: “Urban Indian organization means a nonprofit corporate body situated in an urban center governed by a board of directors of whom at least 51 percent are American Indian/American Natives, for the purpose of establishing and administering an urban Indian health program and related activities as described in Title V of the Indian Health Care Improvement Act.” However, this requirement does not need to be verified by the OSV team, as noted above under Chapter 18 – Board Composition.

Lastly, it is always permissible for any board of directors to request engagement with an OSV team during a site visit. Whether during an entrance conference, an exit conference, or at any other time agreed upon during the visit. Engagement with the site visit team is always recommended, even though not required in this instance.