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  4. Supplement to the Health Center Program Site Visit Protocol: Guidelines and Logistics for Virtual Operational Site Visits

Supplement to the Health Center Program Site Visit Protocol: Guidelines and Logistics for Virtual Operational Site Visits

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Introduction

The purpose of HRSA site visits is to support the effective oversight of the Health Center Program. Operational Site Visits (OSVs) provide an objective assessment and verification of the status of each Health Center Program awardee or look-alike’s compliance with the statutory and regulatory requirements of the Health Center Program. These OSVs may take place in-person or through a virtual OSV (vOSV) format. 

This supplement to the Health Center Program Site Visit Protocol (SVP) provides an overview of modifications taken to adapt the on-site OSV processes to a vOSV format. Site visit teams will conduct vOSVs using the SVP and this supplement.

Resources

The following resources are available to help health centers prepare for their OSVs:

Logistical Guidelines for the Conduct of Virtual Site Visits

Pre-site Visit Preparation

  • The Operational Site Visit team will contact health centers in advance to confirm virtual site visit dates.  HRSA encourages health centers to:

  • Once the health center and the site visit team confirm dates of the site visit, HRSA will send the health center a standard notification about the upcoming site visit. HRSA will also send resources the health center can use to prepare for the site visit. 
  • At least 4 weeks prior to the scheduled OSV start date, the health center participates in a "Pre-Site Visit" conference call with the site visit team and the HRSA representatives.
    • In advance of the Pre-Site Visit conference call, HRSA’s technical assistance contractor, Management Solutions Consulting Group (MSCG), will provide the health center with file sharing and video/phone conference information to facilitate the virtual site visit.

Documentation

  • At least 2 weeks prior to the scheduled start date of the OSV, the health center must provide all documents listed in the SVP and those listed below in the “Supplemental Methodology and Documentation for Virtual Site Visits” section. The health center will upload all documents using the MSCG file sharing platform.
  • The health center should upload documents in the appropriate folders in the file sharing platform. The file sharing platform is organized by each SVP section.
    • A Consolidated Documents Checklist (PDF - 561 KB) is available in SVP Resources to help health centers prepare and organize the documents and materials.
    • Uploaded files should have descriptive file names that align with the documentation referenced in the SVP. For example, the file name for board minutes might be labeled as “Board Minutes” along with the date of the board meeting.
    • The health center may need to upload the same document into more than one folder. 
    • Confidential documents or documents should be uploaded without Personally Identifiable Information (PII) and with enough information for the site visit team to assess compliance with Health Center Program requirements.
  • HRSA will provide the site visit team with the health center’s latest Service Area Competition (SAC)/Renewal of Designation (RD) application and other documents outlined in the Operational Site Visit Documents Provided by HRSA resource before the "Pre-Site Visit" conference call.

Note: If initial documents provided by the health center are insufficient for the site visit team to assess a program requirement, the site visit team may request additional documentation. The health center will need to provide this documentation by the end of the first day of the virtual site visit.

Virtual Site Visit Schedule and Logistics

  • The virtual OSV will occur over the standard 3-day OSV period.
  • The site visit team and the health center will develop a mutually agreed upon agenda for the site visit.
    • The agenda will include designated times for:

      • Entrance/exit conferences;
      • Virtual site tours;
      • Meeting with patient and non-patient board members;
      • Interviews and meetings for the compliance analysis; and
      • Debriefs with the Project Director (PD)/Chief Executive Officer (CEO).
    • Health center staff and board members must be available during the 3-day site visit for the scheduled interviews and meetings required by the SVP.
    • Health centers are encouraged to review the Onsite Interviews and Interactions Resource to prepare.
    • The site visit team will schedule phone interviews and video conferences with health center staff and board members during or outside of business hours, as agreed upon by the health center and the site visit team.
    • Time zone differences between the site visit team and the health center will be taken into consideration when developing the agenda.
  • HRSA Representatives may be present at interviews, video conferences, and site tours.
  • The health center should have staff available to facilitate the use of technology and help ensure sessions using these systems are able to start on time.
  • No recordings are permitted of the virtual site visit, including site tours, interviews, entrance conferences, and exit conferences.

Video Conferencing Expectations

  • When possible, interviews and meetings will be conducted via video conferencing, including interviews with the board of directors.
  • If there are times when software, hardware, or connectivity issues prevent a video connection, then an audio-only connection is sufficient.

Live Virtual Tour Expectations

  • The health center will conduct a live virtual tour for the site visit team of the service site using video conferencing software and the health center’s equipment (for example, phone, tablet, computer camera).

    • If the health center has more than one service site, there will be a tour of at least two service sites.
    • Each tour will include both the exterior and interior of the building, front desk, and clinic (consistent with an “in-person” tour).
    • The site visit team may provide direction to the health center’s “tour guide” if the team wants to review something further.
    • The site visit team may also request to speak informally with staff during the tour.
  • Consistent with the SVP, these virtual tours will be scheduled during the 3-day site visit and, if there are multiple sites, the health center will determine the site tour locations.
  • If the health center is unable to conduct the live virtual tour, in lieu of the virtual tour, HRSA will use the OSV documentation submitted by the health center to assess compliance with related Health Center Program requirements typically assessed through the tour.

Screen Sharing Expectations

  • The site visit team may request screen sharing of documents and systems to facilitate joint review of certain documentation (for example, system walkthrough, Electronic Health Record (EHR) demo, Form 5A walkthrough).

Supplemental Methodology and Documentation for Virtual Site Visits

The virtual site visit will be conducted consistent with the methodology and documentation required by the SVP. However, additional documentation and meetings necessary for a virtual site visit are outlined below. Health centers must submit this additional documentation at least 2 weeks prior to the site visit.

  • General Information

  • Required and Additional Health Services
    • Direct Services (Form 5A: Services Provided, Column I): The site visit team will confirm that each service delivered via Column I is being directly provided by the health center through:

      • Interviews of clinical staff; or
      • If a Column I service cannot be verified through the site tour or interviews, review of at least one health center Column I patient record.
  • Sliding Fee Discount Program
    • Staff walk through the screening and enrollment process for the health center’s Sliding Fee Discount Program using related documents such as standard operating procedures, signage, and forms.
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