Health Center Program Compliance Frequently Asked Questions (FAQ)
Can’t find your answer here? Please submit your question through the BPHC Contact Form and select the appropriate issue type, or call Health Center Program Support at 1-877-464-4772.
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.
Key management staff
This question relates to Element d. CEO Responsibilities
The HRSA Health Center Program regulations at 42 CFR Part 51c refer interchangeably to the PD and CEO. The title of the position may vary by health center. For the purpose of demonstrating compliance with Health Center Program requirements, the PD/CEO is the individual in the health center who:
- Is directly employed by the health center;
- Is selected by the health center's governing board;
- Reports to the health center's governing board; and
- Is responsible for overseeing other key management staff in carrying out the day-to-day activities necessary to fulfill the HRSA-approved scope of project.
Under the Uniform Administrative Requirements for HHS Awards at 45 CFR 75.2, the term "Principal Investigator/Program Director (PI/PD) means the individual(s) designated by the recipient to direct the project or program supported by the grant." The Health Center Program considers the PD/CEO to be synonymous with PI/PD. Therefore, the PD/CEO is the person responsible for the day-to-day management of the Health Center Program project.
If a health center has both a CEO position and a separately identified PD position, the health center would need to show that it is the PD for the Health Center Program project, and not the CEO, that fulfills all applicable requirements noted above. The health center also would need to provide documentation that the PD is directly employed by the health center.
(Updated: 3/8/2023)
This question relates to Element d. CEO Responsibilities
Yes, health centers are required to directly employ the PD/CEO. For the purpose of compliance with Health Center Program requirements, the health center's PD/CEO is an individual who:
- Is directly employed by the health center;
- Is selected by the health center's governing board;
- Reports to the health center's governing board; and
- Is responsible for overseeing other key management staff in carrying out the day-to-day activities necessary to fulfill the HRSA-approved scope of project.
For more information, refer to the Health Center Program Compliance Manual Chapter 11: Key Management Staff.
(Updated: 3/8/2023)
This question relates to Element d. CEO Responsibilities
To demonstrate compliance with the requirement for direct employment of the PD/CEO, a health center, including a public agency health center, as the Health Center Program awardee/designee of record, would directly employ the PD/CEO. Use of a co-applicant structure for meeting Health Center Program governance requirements does not alter this requirement. Please refer to related requirements in Health Center Program Compliance Manual Chapter 19: Board Authority on public agencies with co-applicants.
(Updated: 3/8/2023)
This question relates to Element d. CEO Responsibilities
Yes, the Health Center Program statutory requirement (Section 330(k)(3)(H)(ii) of the Public Health Service Act) that a health center directly employ its PD/CEO applies to any health center PD/CEO serving on an interim or permanent basis.
(Updated: 3/8/2023)
This question relates to Element e. HRSA Approval for Project Director/CEO Changes
Yes, in accordance with grants regulations (45 CFR 75.308(c)(1)(ii) and (iii)), a health center must request and receive prior approval from HRSA when there is a post-award change in the PD/CEO position, specifically when:
- There will be a change in the current health center PD/CEO. For example: a change due to dismissal, resignation, or retirement of the current PD/CEO; appointment of an interim PD/CEO for three months or more; appointment of a new permanent PD;
- The current health center PD/CEO will be absent from the project during any continuous period of three months or more; or
- The current PD/CEO will reduce time devoted to the project by 25 percent or more from the level that was approved at the time of award/designation.
Under the HHS Grants Policy Statement (GPS), a health center must provide written notification to the Grants Management Officer, and a request for prior approval must include all information noted in the GPS (refer to HHS GPS, p. II-56 (PDF)).
(Updated: 3/8/2023)
This question relates to Element e. HRSA Approval for Project Director/CEO Changes
A health center awardee can change its Project Director by submitting a prior approval through the EHBs, using the steps identified in this video.
A health center look-alike (LAL) should use the BPHC Contact Form to obtain guidance on how to change its Project Director in the EHBs.
(Added: 3/8/2023)