Health Center Program Compliance Frequently Asked Questions (FAQ)
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The term “site visit” in these FAQ refers to:
- Operational Site Visits (OSVs) conducted for awardees
- OSVs conducted for look-alikes
- Initial Designation (ID) site visits conducted for look-alike applicants
The information in these FAQ only relates to requirements and processes of the HRSA Health Center Program.
Contracts and subawards
This question relates to Element a. Procurement Procedures
No, in a health center's financial management or procurement procedures, a simple reference to grants regulations at 45 CFR 75 Subpart E does not demonstrate compliance.
To demonstrate compliance with the Health Center Program Compliance Manual Chapter 12: Contracts and Subawards, a health center's procurement procedures would include specific information consistent with the standards set forth in grants regulations at 45 CFR Part 75 Subpart E, as well as any other federal mandates or related requirements for all procurements related to the federal award.
For additional assistance, refer to the HRSA Manage Your Grant website.
(Added: 3/8/2023)
This question relates to Element b. Records of Procurement Actions and Element c. Retention of Final Contracts
Yes, a health center lists all contracts that support the HRSA-approved scope of project that are paid for in whole or in part with federal award funds.
Federal award funds include the Health Center Program (H80) operating grant award as well as any supplemental funding awarded under section 330 of the PHS Act. Therefore, contracts using Health Center Program federal award funds include contracts that use supplemental award funds, such as Coronavirus-related supplemental awards (for example, H8C, H8D, H8E, or H8F awards) or other supplemental awards (for example, Primary Care HIV Prevention awards) as long as:
- The contracts are active; or
- The contracts had a period of performance that ended less than 3 years before the site visit.
If contracts funded in whole or in part by supplemental awards are among the five contracts that use the largest amounts of federal award funds, then those contracts would be reviewed as part of a site visit for the purpose of assessing compliance with contracting and procurement requirements. However, neither the health center nor consultants would single out supplemental-funded contracts or activities for review if they do not meet the SVP sampling criteria. Refer to the Sampling Review Resource Guide as a helpful sampling resource.
Note: Look-alike OSVs do not include a review of Contracts and Subawards or Conflict of Interest elements that are specific to Health Center Program federal award funds. In addition, look-alikes and awardees that receive other HRSA funding are subject to the specific requirements of those awards; however, the OSV does not assess compliance with those award requirements.
(Updated: 3/8/2023)