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DPH proposes co‑applicant board to preserve Healthcare for the Homeless grant eligibility
Summary
Following an HRSA audit finding, DPH proposed creating an 11‑member co‑applicant board (majority consumers) to satisfy federal FQHC governance rules and maintain Healthcare for the Homeless funding; the Health Commission will consider a resolution and follow-up on Oct. 5.
DPH leaders told the Health Commission they must resolve a Health Resources and Services Administration (HRSA) audit finding that the department’s present governance structure does not meet HRSA requirements for federally qualified health center (FQHC) boards.
Hallie Hammer, Director of Ambulatory Care for the Health Network, explained DPH is a subgrantee under the San Francisco Community Clinic Consortium’s Healthcare for the Homeless grant. HRSA’s compliance manual requires an FQHC governing board of 9–25 voting members with specific selection rules. HRSA auditors cited DPH for not meeting those governance requirements during a 2021 operational site visit and subsequent audit.
To address the finding, DPH and the City Attorney’s Office worked with the consortium and crafted a proposed co‑applicant board model. The draft proposal calls for an 11‑member co‑applicant board with a majority of voting members who are consumers of Healthcare for the Homeless services; the initial members would be appointed by the Director of Health and subsequent appointments recommended by the board. The co‑applicant agreement and bylaws would limit the board’s authority where chartered city fiscal and personnel powers apply and would include an ex‑officio, non‑voting member option.
DPH said the consortium must update HRSA by Oct. 5 on progress. If HRSA accepts the plan it can be implemented; HRSA may also request changes or require a full rework with a short compliance timeline. The Health Commission will review a draft resolution and the co‑applicant agreement and will consider action at a future meeting (scheduled for Oct. 5).
