Typically, peer review is completed only for Licensed Independent Practitioners (LIPs), although some high performing health centers do complete peer review for OLCPs. HRSA does not require peer review to be completed for OLCPs and OCS, but the health center must have some type of method in place for verifying competency and evaluating performance on an ongoing basis. This can be accomplished through the completion of annual competencies and what is often considered chart review. In the case of OLCPs and OCS, the tool being utilized to conduct the chart review is tailored to the specific skills for the scope of licensure (if a licensure, registration or certification is applicable), as well as the job responsibilities outlined in the job description.
The health center is not required to include OLCPs and OCS in the Peer Review Policy and Procedure for LIPs, although the health center should maintain a separate document(s) outlining the process utilized to evaluate the performance/competency of these categories of clinical staff.
Regulators are no longer satisfied with documentation alone; they want evidence that your compliance program actively prevents, detects, and corrects risk. Investigators expect to see how issues are identified early, investigated thoroughly, corrected effectively, and monitored over time. Boards demand measurable insight, and leadership needs confidence that exposure is managed before it becomes a liability. The standard has shifted from activity to impact.