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.
Conflict of interest
This question relates to Element a. Standards of Conduct and Element d. Adherence to Standards of Conduct
Yes, a health center board member can be a contractor or supplier to the health center and continue to serve on the board if the board member discloses the conflict of interest and does not participate in the selection process of any contract that has a conflict of interest. The health center determines the appropriate methods for board members to disclose real or apparent conflicts of interest.
For more information, refer to 45 CFR 75.327(c)(1), the HRSA Conflict of Interest Policy, and the Health Center Program Compliance Manual.
(Updated: 10/24/2023)
This question relates to Element a. Standards of Conduct
Yes, a board member is allowed to be employed by or contract with another health center, as long as:
- The board member does not have a real or apparent conflict of interest with the other health center;
- The board member complies with the methods of both health centers for disclosing real or apparent conflicts of interest;
- The board member complies with both health centers' standards of conduct when involved in the selection, award, or administration of contracts paid for in whole or in part by the Federal award; and
- The health center that employs or contracts with the board member follows standards of conduct related to procurements paid for in whole or in part by the Federal award.
Refer to Health Center Program Compliance Manual Chapter 13: Conflict of Interest and to Health Center Program Compliance Manual Chapter 20: Board Composition for additional requirements that may impact board members.
(Added: 3/8/2023)
This question relates to Element a. Standards of Conduct and Element d: Adherence to Standards of Conduct
No, when a site visit team assesses compliance with the Health Center Program Compliance Manual Chapter 13: Conflict of Interest, the site visit team does not review signed disclosure statements or forms from all health center staff and board members. If a health center identified a real or apparent conflict of interest for any procurement that occurred within the last three years and that was paid in whole or in part by the Federal award, the site visit team reviews all related written disclosures. These written disclosures (for example, board minutes documenting disclosures, standard forms to report disclosures) would be completed by employees, officers, board members, and agents of the health center.
(Updated: 3/8/2023)