This webinar discusses continuous compliance for health centers, focusing on requirements from HRSA Compliance Manual Chapters 15 (Financial Management & Accounting) and 17 (Budget). It provides an overview of key elements for each chapter, tips for successful OSV preparation, and strategies for maintaining compliance ongoing rather than just for site visits. Maintaining accurate financial tracking systems, following drawdown and expenditure procedures, and involving staff in annual budgeting are emphasized.

1. www.compliantfqhc.com
Continuous Compliance Series- It’s not JUST an
OSV Prep
COMPLIATRIC WEBINAR SERIES
Presented by: Tonya Harris
marketing@fqhcwebinar.com

2. CONTINUOUS
COMPLIANCE
-IT’S NOT JUST AN OSV PREP-
Chapter 15 Financial Management & Accounting
Chapter 17 Budget

3. DISCLAIMERS
This presentation is not endorsed by Management Strategists Consulting
Group (MSCG)
This presentation is not endorsed by Health Resources Services
Administration (HRSA) or Bureau of Primary Health Care (BPHC)
Not employed by MSCG or BPHC
Independent Consultant who is contracted to do Operational SiteVisits
(OSV)s and Technical Assistance (TA)
Not intended to provide legal advice

4. WHY THE COMPLIATRIC SERIES?
Continuous Compliance
Monthly focus on various HRSA Compliance
Chapters
Provide additional resources to include best
practices for preparation of the OSV
What are the requirements?
Use compliance to be a generative health
center (higher functioning)
VisitVirtual visits will continue to be the primary mode of assessing compliance
for the foreseeable future
365 site visits are planned for 2022

5. AGENDA
UNDERSTANDING OF THE
PROGRAM REQUIREMENTS WHICH
INCLUDES UPDATES TOTHE SITE
VISIT PROTOCOL (SVP)
MAINTAINING CONTINUOUS
COMPLIANCE NOT BASED ON A
SITEVISIT
IMPROVING OPERATIONAL
EXCELLENCE FORYOUR HEALTH
CENTER

6. TIPS FOR SUCCESSFUL OSV
• Upload documents timely
• Use naming convention
• Only give required sample
• Make sure sample loaded is compliant
• Indicate required information within the document
• Make sure that the uploaded Form 5A is the MOST current
• Include appropriate staff in interviews

7. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
Element – A Financial Management and Internal Control Systems
• Must be able to track actual expenditures in comparison to the
Health Center Program project budget
• Must have capacity to account for the expenditures of Health
Center Program project funds, and the use of associated assets and
property
• Must demonstrate capacity to track its financial performance for
the purposes of monitoring financial stability

8. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
• Element B – Documenting Use of Federal
Funds
• Health Center Financial Management Systems
must be able to track related expenditures made
under the award
• Chart of accounts
• Internal tracking procedures

9. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
• Element C – Drawdown, Disbursement, Expenditure
Procedures
• Written procedures for drawing funds with the following provisions:
• Limit the drawdown to minimum amounts needed to cover allowable project
costs
• Time drawdowns in a manner that minimizes the time elapsing between the
transfer of the federal award funds from HRSA and the disbursement of these
funds by the health center.
• Ensure all expenditures utilizing federal award funds are allowable in accordance
with:
• The terms and conditions of the federal award, including those that limit the use of
federal award funds
• The federal cost principles in 45 CFR Part 75 Subpart E

10. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
• Element D – Audits and Responding to Findings
• Any Health Center awarded more than $750,000 is required to have an
annual audit
• Was the audit performed timely
• Were there any
• questioned or unallowable costs
• reportable conditions
• material weaknesses
• significant deficiencies

11. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
Element D – Audits and Responding to Findings (continued)
• Was corrective action taken and the issue resolved?
• Corrective Action Plan
• Resolution must be documented in Board Minutes

12. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
• Element E – Documenting use of Non-Grant Funds
• Health Centers who generate revenue from health center activities
and then use the revenue for activities outside the scope of project
• Must have documentation to prove that these funds
• were used to support activities that benefited the current patient
population, and
• were for a purpose NOT specifically prohibited by the Health
center Program

13. CHAPTER 15 - FINANCIAL MANAGEMENT &
ACCOUNTING SYSTEMS
Continuous compliance
• Include specific language in the drawdown policy and procedure
• Copy and paste directly from compliance manual when possible
• Schedule Annual Audit soon after the year end so that you can have the
most current audit
• If you have an audit finding:
• Create action plan
• Present to the board when plan is created and upon completion
• Make sure you can prove the correction has been made

14. CHAPTER 15 – FINANCIAL MANAGEMENT
OPERATIONAL EXCELLENCE
• Know your software’s capabilities and utilize them
• Structure Chart of Accounts so that they are easily expandable
• Review and Update Financial Policies annually

15. CHAPTER 15 - FINANCIAL MANAGEMENT

16. CHAPTER 17 - BUDGET
• Element A - Annual Budgeting for Scope of Project
• Annual Operating Budget reflective of the projected costs and revenues to support
HRSA approved scope of project
• Does the budget reflect revenue and expenses for all services, sites, and activities
• Departmental budget
• Budget to Actual comparison
• Operational vs HRSA budget

17. CHAPTER 17 - BUDGET
• Element B – Revenue Sources
• Element C – Allocation of Federal and Non-Federal Funds
Both elements B & C are assessed through the SAC and not part of the OSV

18. CHAPTER 17 - BUDGET
• Element D – Other Lines of business
• Does Health Center engage in other lines of business
• Serve other populations or operates the following not in HRSA Scope of
service
• Other Populations
• Sites
• Services
• Documentation proves that these other lines of business are
• Supported fully by non-health center projected revenue
• Expenses are excluded from the annual operating budget for health
center project

19. CHAPTER 17 - BUDGET
-OPERATIONAL EXCELLENCE-
• When creating the budget, input from all departments is imperative
• Staff feel ownership when they helped create the budget
• Creates team accountability
• Share information - both positive and negative
• Celebrate successes
• Challenges are identified and addressed quickly, minimizing impact
• Monthly &Yearly Budget to Actual comparison
• Vital information for the Leaders of the organization to make informed decisions
• Information shared should show progress or identify challenges quickly

20. CHAPTER 17 – BUDGET
Continuous compliance
• Develop a Procedure that
• Includes staff input
• Defines major elements
• Provider productivity
• Revenue per visit
• Full time Equivalent
• Historical Cost

21. QUESTIONS

22. RESOURCES
HRSA Health Center Compliance Manual
•https://bphc.hrsa.gov/programrequirements/compliancemanual/index.html
HRSA Health Center SiteVisit Protocol
•https://bphc.hrsa.gov/programrequirements/site-visit-protocol
HRSA Scope of Project (Form 5A Services Provided)
•https://bphc.hrsa.gov/programrequirements/scope/documenting
NACHC-Health Center Resource Clearinghouse
•https://www.healthcenterinfo.org/