HRSA Operational Site Visits - what are they, what you can expect, and how you can prepare as a health center.
You just received a call from your Health Resources and Services Administration (HRSA) project officer telling you of your upcoming Operational Site Visit (OSV). Before panic sets in, take a moment to review this article. Take a deep breath and relax, your Primary Care Association is here to provide you with technical assistance to make your HRSA OSV a total success.
So what is the point of the HRSA OSV anyways?
These visits are designed to perform a full organizational assessment in all operational areas (fiscal, clinical, administration/ governance). Every health center will have an operational assessment at least once per project period (read every 3 years). Operational assessments are usually 3 days on site and your HRSA Project Officer/Branch Chief may or may not attend.
The key to remember here is that the entire focus of the OSV is to ensure that your health center is meeting the Program Requirements. This previous link provides a breakdown of each of the components and how to comply with each.
Requirements are divided into four categories:
- Management & Finance
NOTE: Portions of program requirements indicate regulatory requirements that are recommended but not required for grantees that receive funds solely for Health Care for the Homeless (section 330(h)) and/or the Public Housing Primary Care (section 330(i)) Programs.
So what can you expect?
Pre Site Visit Conference Call:
Purpose: to introduce the site visit team: Administrative/Governance Consultant; Financial Management/Information Management Consultant; and the Clinical Consultant. This could also include the HRSA Project Officer and Branch Chief.
The call will describe the purpose of the site visit (Program Requirement compliance/technical assistance where possible); the on-site process (entrance and exit conferences, agenda, management staff availability, document list (hard copy/digital); the Board member interview/meeting; site tour; and onsite logistics including work area. You will confirm the site visit location and they will answer any questions.
CHC’s Pre Site Visit Preparation:
OK, now you know the site visit is happening - how do you prepare?
- Ensure all staff aware of Site Visit date and their roles in a successful visit
- Review Program Requirements with Board and staff
- Review this Health Center Site Visit Guide to help with preparation
- Ensure management team/board member(s) available for first and last day of site visit
- Ensure CMO/Providers allocate time to meet with the Clinical Consultant
- Prepare documents and send to Site Visit team as requested prior to their visit
What to expect - a sample agenda:
8:30 AM – 10:00 AM - Entrance Conference: (Project Officer leads if present); Introduce Consultant Team/Purpose of the Site Visit; Health Center Overview- Senior Management Team/ Executive Director
10:00 AM - 12:00 PM - Meet with Members of Senior Management Team on individual basis (CFO,Medical Director, Exec. Director, Board Representative, etc.)
12:15 PM - 1:30 PM - Lunch with Board Members (at least members of the Executive Committee)
2:00 PM - 3:00 PM - Tour Facility
3:00 PM - 5:00 PM Continue Meeting with Senior Management Team and Center Staff
9:00 AM - 4:00 PM - Continue Meeting with Senior Management Team and Center Staff, Information Gathering/ Document Review
9:00 AM - 11:00 AM - Continue Meeting with Senior Management Team and Center Staff, Information Gathering/Document Review
11:30 AM-2:30 PM - Finalize Technical Assistance recommendations
2:30 PM – 4:00 PM - Exit Interview (Project Officer leads if present); Consultants summarize findings
4:00 PM - Team departs
What to expect - Visit Entrance Conference:
- Describes onsite process and outcome
- Lasts about an hour
- Team/staff introductions
- Set onsite expectations
- Reviewers expecting CHC Leadership/Board describes successes, challenges and opportunities for improvement, organizational priorities, and potential technical assistance needs. (Can be done in Powerpoint or Prezi)
What to expect - Interviews & Document Review:
- Site Visit team’s approach may vary where one member may read first and talk later - others may not
- Management & staff Interviews:
- Site Visit team will seek clarification of policies and procedures
- What do you do
- Who reports to whom
- Verifies practices are consistent with policy
- Assesses job tasks, duties and responsibilities are consistent with observed practices
- Who’s running the organization
- Site Visit team obtains an overall impression of grantee financial and operational performance and status based on expertise and available documentation
- Site Visit team determines compliance with Program Requirements and identifies areas for performance improvement (must and should)
- Identifies best practices
Health Center Board’s Role during HRSA OSV:
- Board members are requested to attend the entrance and exit conferences
- Usually there is a separate meeting with Board
- Board members could be asked about the following:
- Assessment of Center financial, operational and clinical performance
- Program Requirements
- Strategic Plan
- Financial Reporting and Status
- Quality Assurance Plan
- Information systems/informatics
- Performance reporting
- Overall management performance
- Board performance and self evaluation
Project Officer’s Role during HRSA OSV (if present):
- The Project Officer (PO) is the HRSA on-site representative but does not manage the visit, work flow, process and or product
- Opens & closes the site visit (entrance & exit conference) & explains post onsite process
- Observes (shadows) consultants’ work process (interviews) but is not a participant except in cases of specific findings set forth in the Notice of Award (NOA)
- The PO’s presence at interviews can change the dynamic and sometimes puts a brake on health center staff openness. If this occurs the Consultant may do a follow up interview
- If team performance issues arise on-site, consults with the Team Leader for resolution
- Consults with Team about the application/interpretation of HRSA policy, but ultimately it is the consultant’s decision as what goes in the initial report
Site Visit Team’s Roles during HRSA OSV:
- The Team Leader:
- Manages the site visit
- Ensures the agenda is followed and that all Program Requirements are addressed
- Facilitates effective communication among the Team regarding findings and recommendations
- Resolves onsite performance issues
- Leads/facilitates entrance and exit conferences
- Team introductions
- Establishes order of presentation of preliminary findings and recommendations at exit conference
- Other Team Members:
- Completes document review and interviews (board, management and other staff – consultant choice) within their disciplines
- Prepares preliminary report addressing Program Requirement compliance (“Met”, “Not Met”); Performance Improvement recommendations and Technical Assistance (TA) recommendations
Oregon Primary Care Association's (OPCA) role during HRSA OSV:
- OPCA is available over the phone to answer questions as well as provide data that may provide some context during the OSV
- We can have data available that compares your CHC to state and national quality metric averages
- Listen and learn! Site visits are a great forum for us to learn and share our learning with other sites that are preparing for site visits
- During the exit interview there is a review of suggested/required opportunities for improvement. OPCA can help you with those improvements, if needed/desired. We have a network of clinics that are able and willing to share policies, procedures, workflows so that you may not need to re-create the wheel
- If OPCA’s presence on the phone during the exit conference is in any way uncomfortable to the organization, we do not need to attend – it’s completely up to the health center. It’s OPCA’s intention to be invited in and be value added, as needed
What to expect - Exit Conference:
- Identifies post onsite process including report preparation and distribution
- Consultants report preliminary summary:
- program requirement compliance
- findings and recommendations
- Performance improvement areas
- Brief questions but no debate since grantee will have an opportunity to respond to the report
- Project Officer describes post onsite process
What is in the report?
- Basic information-grantee name, and address, consultant(s) and their review areas
- Overview of the grantee- some history, population and target area demographics, information relevant to the grantees current operations
- Participants and if they were interviewed and attended entrance and exit conferences
- List of documents reviewed
- List of documents left with the grantee
- Primary Compliance Issues, Concerns, and/or Performance Improvement Opportunities Addressed During Visit
- Four Sections that follow the Health Center Site Visit Guide; Section I- Need; Section II –Services; Section III - Management and Finance; Section IV-Governance
- Each section is populated with the applicable Program Requirements and Performance Improvement recommendations
- Targeted Technical Assistance- the consultant is asked to address a specific area such as the governing board, financial concerns, clinical/quality assurance, etc. Only the Section(s) and Program Requirement(s) that are applicable are required to be addressed in a targeted TA report
Met and Not Met:
For Operational Site Visits all Program Requirements need to be designated as either “Met” or “Not Met” based on the consultant’s review and judgment of the grantee’s operational/implementation response to the Program Requirements.
If “Not Met”, there will be a finding that provides information on the grantee operations that shows why the requirement is not met. There is not a recommendation for a “met” PR.
Although a requirement may be designated as “Met”, there still may be a finding and recommendation under the Performance Improvement Area (PIA) that provides performance improvement guidance to the grantee on a way to further improve some aspect of the grantee’s operation.
If the designation of the requirement is “Not Met”, there will be a finding that specifically addresses what part of the program requirement is not met (some of the requirements have multiple parts) and a recommendation that specifically provides guidance to the grantee on what action(s) need to be taken to bring that portion of the operation back into compliance.
There may also be performance improvement findings and recommendations under a “Not Met” that provide additional guidance to the grantee on ways to improve other aspects of the operation that are related to the program requirement. The grantee will be given the opportunity to respond to the item mentioned in the report prior to it becoming final; however, the report cannot be changed to reflect any updates or changes that have occurred after the completion of the site visit.
What the Findings Mean to the Health Center:
- For Program Requirements that are a “Not Met”, a condition will be placed on the NOA and the grantee will interact with the project officer and the HRSA Office of Grants Management to address and resolve the condition
- The report may also contain many recommendations to the grantee that are guidance to improve various aspects of the grantee’s performance. The project officer and grantee will work together to address the recommendations. This may take the form of an action plan or the recommendations may be addressed in ongoing dialogue between the project officer and the grantee.
- The project officer may also determine, either for a performance improvement recommendation or for a Program Requirement concern, that additional technical assistance is needed by the grantee
OSV Follow Up Visit:
After an Operational site visit occurs, an on-site follow-up visit may be conducted to provide additional consultation, targeted technical assistance or validate progress. These visits may be conducted by the project officer and/or consultant(s), and the duration will be determined by the type and complexity of support or assessment required.
Bottom Line for the Health Center:
- Cooperate with the Project Officer and Site Visit Consultants
- Be transparent! Communicate! Prepare!
- If conditions on NOA, then work aggressively and expeditiously to resolve. OPCA can help!
- Keep your Project Officer updated on the status of your Corrective Action
- Show yourself off – Brag a little!