Compliance Resolution Opportunity (CRO)

The purpose of the OSV CRO program is to allow health centers to resolve preliminary findings of non-compliance identified during the OSV via the Compliance Resolution Opportunity (CRO).

After the OSV, but before the OSV report is finalized by HRSA, HRSA will send a request to submit documentation to resolve these preliminary findings of non-compliance.  These will be sent through Electronic HandBook (EHB).  

You will have 14 calendar days from the date of the EHB correspondance request to respond.  If the response is acceptable, HRSA will not apply a condition for that element.  If your response is unacceptable, HRSA will apply a progressive action condition for each non-compliant element.  

FQHC Consultants is here for you!  We guarantee that our assistance during this process will result in no condition for the non-compliant element.  If for any reason your non-compliant element becomes a condition, we will stand behind you and, at no additional charge, work with you through the process to get the condition removed! 

Contact us before your exit conference to engage for a nominal retainer fee.  This covers our review of your notes of non-compliance (in many cases, a consultant can listen in on your exit conference as scheduling allows).  If it ends up you have no conditions, you get this refunded or you can use the retainer how you like on any FQHC Consultants, Inc. services for the next 12 months at the reduced client hourly rate.  



The purpose of the Look-Alike designation is to expand these types of service delivery sites to underserved and vulnerable populations.  Look-Alikes were established under the health center program to maximize access to care for medically underserved populations and communities by allowing entities that do not receive full health center status (under a New Access Point or a Service Area Competition) to apply to become part of the Health Center Program and, once designated, become eligible for the benefits of being in the program.

The benefits of being in the program are considerable.  While Look-Alikes do not receive annual grant funding (like their counterparts who are fully deemed grantees) they are eligible for enhanced reimbursement from the Medicaid and Medicare programs under the Federally Qualified Health Center (FQHC) Prospective Payment System (PPS). Other benefits include the ability to purchase drugs for use in the clinic at reduced amounts through the 340B Federal Drug Pricing Program, receive automatic Health Professional Shortage Area designation, and access to hiring and retention of providers through the National Health Service Corps.  

Once a practice has transformed into a Look-Alike, there are renewals and annual certifications involved depending on where in the current designation period the Look-Alike entity is.  It is critical to maintain compliance with the program and demonstrate this compliance as needed and FQHC Consultants, Inc. is here to help do just that!


All Health Resources Services Administration (HRSA) grantees and look-a-likes must report on a number of operational and quality issues annually.  We offer reporting services for filing HRSA reports including, but not limited to, Uniform Data System (UDS), Federal Financial Report (FFR), Budget Period Report (BPR), and project-specific reporting including capital grants, outreach and enrollment, and others . 

For full reporting required for specific health centers, if appointed, we monitor the Electronic Hand Book (EHB) site specific to your health center for tasks due and other deadlines and keep you compliant!  We can simply review reports and give a second opinion before you submit or build them from the ground up.  While we are never listed as authorizing officials in EHB for your health center, we are listed as single points of contact (SOPs) and business officials on many for this monitoring service.

We can also act as your HRSA Electronic Hand Book (EHB) representative to file any additional grants, update your forms 5A, B and C for scope, file Changes in Scope, and other submissions as they are necessary to keep your health center compliant.  



Many health centers have great operations and perform well in their clinical and financial measures.  Many have excellent Quality Improvement/Quality Assurance Programs (QI/QA).  We guide our clients to use this framework across the operation to fuel transformation.  Key Performance Indicators (KPIs)  such as patient access times, visit cycle times, productivity measures including Relative Value Unit (RVU) analysis, and various costs per visit and RVU are benchmarked against internal targets and baselines, private industry KPIs, as well as national and state health center data. 

This addition of operational and financial KPIs  to the more traditional clinical KPIs and including them in the QI/QA process transforms health centers into highly performing ones.  Engaging the finance and operations staff in the QI/QA process with measures for which they are accountable firmly solidifies teams across the organization.

A reporting platform is built specific to your health center including a weekly dashboard and a monthly operating review.  The weekly dashboard concentrates on provider productivity, patient access measures, phone system performance, utilization, and other KPIs important to your health center's success.  The Monthly Operating Review adds financial and quality measures with a monthly roll-up of the weekly dashboard to give an "at a glance" dashboard for the key staff, board of directors, providers, and support staff to see how the system is performing.  

The dashboard is specific to the provider and can be enhanced for specific reporting of service areas, service sites, or any combination of these.  Once this platform is launched in your health center, our staff can be engaged to help monitor the reports and give recommendations, best practices, and suggest levers to enhance operations.  Many health centers find that simply launching this system showing the achieving of metrics (shown in green), opportunities for success (shown in red), and improved performance approaching success (shown in yellow) cause system transformation, sparked productivity, and a new ownership of activities by staff at all levels.  CLICK HERE TO DOWNLOAD A PRESENTATION



Now that we have the final Health Center Compliance Manual (click  here for your copy) an upcoming HRSA site visit can be a challenging time for most health centers.  Even if you are not scheduled for your site visit, best practice is to take one piece of the guide and work on it each month to ensure compliance.  

FQHCs, RHCs, and Look-A-Likes must remain compliant across 19 program requirements with thousands of individual elements.  Once each grant period, all Section 330 grantees will have a HRSA Operational Site Visit (OSV)The first one for new grantees fills CEOs and staff with fear and stress.  It doesn't have to be this way.  Our team of consultants can take every aspect of the new Health Center Compliance Manual and analyze your operation to ensure compliance.  We review policies, procedures, board operations, financial operations, etc. to determine what changes may need to be made in order to make your site visit a success.  

Most of this analysis is done remotely to save costs but one to two days of on-site meeting with the board of directors, the executive team, the providers, and staff is required to fully prepare the facility for the inspection.  Where deficiency is noted, you will be given the materials, customized to your health center, that are in compliance with the program.



Many health centers have computerized practice management and electronic health records systems in place.  Many use some type of accounting package or reporting system.  Many of those do not use them to their fullest and may be suffering operational and productivity opportunity loss that can be corrected. 

Our team of experts is already familiar with many of the popular systems used by health centers.  Our team is called in to perform projects ranging from small workflow enhancements to complete system re-implementations.  

Have a new system to bring online?  Some health centers call us in to study their operation and assist in new software implementations alongside the teams usually provided by larger software vendors to ensure implementation is compliant with the 19 program requirements.  We can maximize use of these systems to make UDS and grant reporting less onerous as well as help create productivity, quality, and meaningful use accountability enhancements.



Most health centers are sitting on a gold-mine of contacts for community outreach and awareness activities.  Properly implemented, a community outreach and awareness plan can add new patients, regain past patients, and cement new partnerships to grow unique patient counts, reportable visits, and often cash flow.  

FQHC Consultants, Inc. has a program that is tailored to the specific needs and community of your health center.  This program is a grass-roots effort which does not rely on expensive media campaigns.  It is a program of direct mail, email, fax, SMS, phone messaging, and outreach coordination with your staff to build your brand awareness and the benefits you offer to all.  This program works in tandem with your other activities to produce solid results.



Many small health centers simply cannot afford a fulltime CFO or the CEO is performing these duties.  For accountability and true financial and operational strength, the CFO should be a separate person.  We are able to perform as CFO for your organization and assist your internal accounting team with organization of reports, reporting to the board (using Skype or webinar at your board meetings), and assisting with all of the CFO functions required by HRSA.  We monitor the financials, make recommendations to the CEO and others designated by the CEO, counsel providers on productivity and profitability, counsel office and front managers on collections, etc.



Some health centers make the decision to bring billing in-house and others decide to use billing services.  No matter what your decision, we can handle it for you or help monitor your in-house operation.  We have a team of billers who can also act as backup when  you are under heavier than expected charge or payment posting load.  They can also help analyze denials and remittance advices to ensure you are maximizing collections.  Our billing services team can use your web-enabled software system or recommend one of several that we have used.



The UDS report is the report card issued by health centers to HRSA and now, the world.  Quality metrics rate health centers against one another and report the quartile the health center falls within with regard to the quality metrics.  HRSA also monitors established health centers' financial and operational health by reviewing UDS submissions against the rest of the nation and those around them.  It is vital that UDS submissions accurately reflect the true picture of the health center's operations and that they are benchmarked before submission to identify and explain major variances.  Our team of consultants can help by monitoring the UDS throughout the year and make sure there aren't any surprises when UDS runs the first week of January.  We have a limited number of slots available each year for this assistance so register early if you need this help!


Many small health centers simply cannot afford a full-time grant writer. The result is that their grant applications are often rushed, incomplete, and may not properly reflect the true benefit your health center would have on the people served by the grant to which you are applying.  This can be the Service Area Competition, a New Access Point, your Budget Period Update, a Capital Grant, or any number of HRSA incremental funding opportunities or private foundations. Every dollar is critical isn't it?

Unlike years past, today's Service Area Competitions (SACs) are not simply automatically awarded to the incumbent grantee.  They are competing competitions and there have been cases where incumbents lose out to other grantees wishing to take over or new grantees altogether with better grant proposals.  Care must be taken to carefully and completely answer the grant request including justification of the unique patient counts the project will care for before the end of the project period. 

While it is true that the history of conditions on the grant may not directly impact the successful awarding of the grant application, each grant application must clearly define and demonstrate how the grantee is in compliance with all  program requirements and how it will maintain this compliance throughout the period of the grant.  The application also must clearly demonstrate the unique benefit the grantee offers to fulfill the project at hand.

Equally critical are the Budget Period Updates (BPRs) required every year with the second year update being most critical as it will be used in the OSV that will follow.  Many health centers don't have the staff time to alot to this very important work.  FQHC Consultants can handle this for you on a project basis helping you align your grant with your strategic plan.  Your health center's financial picture is clearly defined to cast it in the best light.  The progress you have made is detailed along with specific issues that may be restricting or contributing to the success of your overall program and each individual sub-award.  Your zip codes are analyzed to ensure you are maintining a proper scope of project.  A survey of all areas of compliance is also conducted in an efficient manner that will address any items that might require additional work.  



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