The Importance of Pre-SAC Compliance Reviews for FQHCs

FQHC's, Health Center Program, HRSA Compliance, Service Area Competition, Grant Applications, Community Health, Healthcare Compliance, Board Governance, FQHC Policies, Community Link Consulting 

Understanding the SAC Application Challenge 

The Service Area Competition (SAC) grant is the primary funding mechanism for most FQHCs, making it one of the most critical applications your organization will submit. Unlike some non-competitive federal grants, the SAC is truly competitive, meaning other organizations can compete for your service area. If your SAC application doesn't demonstrate full compliance with Health Center Program requirements, it increases your risk of not receiving the award. 

The SAC Application Timeline Challenge: 

  • The typical SAC application allows only 30-60 days from NOFO publication to submission deadline 

  • All policies and procedures referenced must be current and Board-approved 

  • Operations described must align with written policies 

  • Content must demonstrate compliance with the latest federal guidelines and expectations 

Why Pre-SAC Compliance Reviews Matter 

Identifying Compliance Gaps Early 

Many health centers discover compliance issues during the SAC writing process, when time is already limited. Attempting to address these issues while simultaneously writing a SAC application often results in rushed policy updates and misaligned narratives. A pre-SAC compliance review identifies gaps months before your application is due, giving you adequate time to make thoughtful corrections and ensuring your application accurately reflects your operations. 

Addressing Board Governance Challenges  

Most compliance issues requiring correction involve policies that need Board approval. Since Board meeting schedules rarely align perfectly with SAC deadlines, identifying needed changes early allows for proper review and approval within regular meeting schedules. This prevents emergency Board meetings or rushed approvals that may compromise governance quality and documentation. 

Keeping Pace with Evolving Requirements  

HRSA requirements continue to evolve, often with minimal official guidance. Recent federal priorities have emphasized expanded accessibility, data-driven quality improvement, enhanced financial oversight, and strengthened sliding fee discount programs. Your policies may meet previous standards but fall short of current expectations, putting your application at risk. 

Gaining a Competitive Edge  

In today's increasingly competitive federal funding environment, other organizations may target service areas where existing grantees show compliance weaknesses. A comprehensive pre-SAC review ensures you present the strongest possible application, demonstrating your organization's commitment to program integrity and continuous improvement. 

Common Compliance Issues and Review Process 

Our experience assisting health centers with SAC applications has revealed several recurring compliance challenges, including outdated policy references, missing required elements in key policies, insufficient Board documentation, and discrepancies between policies and actual operations. Many health centers also struggle with demonstrating appropriate Board oversight, maintaining complete consumer Board member representation records, and documenting quality improvement activities.  A comprehensive pre-SAC compliance review addresses these issues through: 

Policy Assessment and Operational Review  

We systematically review all Health Center Program-required policies against the current HRSA compliance manual, identify gaps, and evaluate how well your operations align with written policies. This includes reviewing Board minutes and governance documentation to ensure they demonstrate appropriate oversight of health center operations. 

Gap Analysis and Implementation Support  

After identifying compliance issues, we provide a prioritized action plan with timeline recommendations, focusing on which issues require Board approval. We offer templates for policy updates, guidance on documenting operational changes, and project management to ensure all gaps are addressed before your SAC application deadline. 

 

How CLC Can Support Your Pre-SAC Compliance Review 

Community Link Consulting brings extensive experience in HRSA compliance and SAC application success to support your health center. Our comprehensive pre-SAC compliance services include summarizing the latest federal updates, conducting thorough policy reviews, drafting updated policies that meet current HRSA expectations, coordinating with your Board's meeting schedule, and providing project management throughout the process. 

The Bottom Line: Proactive Compliance Saves Time and Secures Funding 

Conducting a compliance review ahead of your SAC application reduces the risk of being deemed ineligible for funding, allows your team to focus on crafting a strong narrative rather than fixing compliance issues, and provides assurance that your application accurately reflects compliant operations. When you begin writing your SAC with confidence in your compliance status, you can focus on what matters most - demonstrating the impact your health center has on the community you serve. 

As always, Community Link Consulting is committed to supporting your health center's success. Please do not hesitate to contact us for more information about our pre-SAC compliance review services or to discuss your specific needs. 

Phone: 509-226-1393 
E-mail: info@communitylinkconsulting.com 

Shelby Maidl, CLC Consultant/Grant Specialist