Progressive Action Conditions Library: Frequently Asked Questions

  1. What is the purpose of the Progressive Action Conditions Library?

    When HRSA determines a health center is not demonstrating compliance with one or more of the Health Center Program requirements, a condition(s) is placed on its award/look-alike designation. To ensure clarity and transparency, each element within the Health Center Program Compliance Manual has a corresponding condition. Each condition includes a description of the specific action(s) needed to remove the condition.

    The Health Center Program library of standard conditions  follows the Progressive Action policy and process and fully aligns with the Health Center Program Compliance Manual. In addition, whenever updates are made to the Health Center Program Compliance Manual, any impacted conditions are also updated and aligned with such changes.

    For more information on the Progressive Action process, please see the Health Center Program Compliance Manual, Chapter 2: Health Center Program Oversight.

  2. Which conditions include a 120-day implementation phase to accommodate the additional time that may be needed for health centers to implement significant programmatic and organizational changes?

    The five conditions listed below allow the opportunity, should it be necessary, for the submission of an action plan for demonstrating compliance. Upon approval of this plan, HRSA would include the 120-day “Implementation Phase” condition for the health center to implement the HRSA-approved action plan and submit appropriate documentation that demonstrates compliance.

    • Required and Additional Health Services-a: Providing and Documenting Services within Scope of Project (aligns with Demonstrating Compliance element a)
    • Clinical Staffing-a: Staffing to Provide Scope of Services (aligns with Demonstrating Compliance element a)
    • Sliding Fee Discount Program-I: Evaluation of the Sliding Fee Discount Program (aligns with Demonstrating Compliance element I)
    • Board Authority-a: Maintenance of Board Authority Over Health Center Project (aligns with Demonstrating Compliance element a)
    • Board Composition-f: Utilization of Special Population Input (aligns with Demonstrating Compliance element f)

    Health centers may refer to the language in the individual conditions for more information.

  3. Are there any conditions that may impact Federal Tort Claims Act (FTCA) deeming determinations?

    A health center’s future FTCA deeming determination may be impacted if the health center has a condition in one of the following areas:

    • Clinical Staffing-c: Procedures for Review of Credentials (aligns with Demonstrating Compliance element c)
    • Clinical Staffing-d: Procedures for Review of Privileges (aligns with Demonstrating Compliance element d)
    • Clinical Staffing-e: Credentialing and Privileging Records (aligns with Demonstrating Compliance element e)
    • Quality Improvement/Assurance-a: QI/QA Program Policies (aligns with Demonstrating Compliance element a)
    • Quality Improvement/Assurance-b: Designee to Oversee QI/QA Program (aligns with Demonstrating Compliance element b)
    • Quality Improvement/Assurance-c: QI/QA Procedures or Processes (aligns with Demonstrating Compliance element c)
    • Quality Improvement/Assurance-d: Quarterly Assessments of Clinician Care (aligns with Demonstrating Compliance element d)
    • Quality Improvement/Assurance-e: Retrievable Health Records (aligns with Demonstrating Compliance element e)
    • Quality Improvement/Assurance-f: Confidentiality of Patient Information (aligns with Demonstrating Compliance element f)

    Health centers would also need to demonstrate compliance with requirements related to risk management and claims management in order to obtain a positive deeming determination. For more information on FTCA deeming requirements, refer to the Health Center Program Compliance Manual, Chapter 21, Federal Torts Claim Act (FTCA) Deeming requirements.

Date Last Reviewed:  May 2019