The Health Resources and Services Administration (HRSA) Health Center Compliance Manual defines Fitness for Duty, formerly referred to as “health fitness,” as the ability to perform the duties outlined in the job description in a safe, secure, productive and effective manner (Fitness for Duty).  Fitness for Duty is considered a privileging activity, as it relates to the health center’s credentialing and privileging process and is required for both initial credentialing and privileging and reappointment for all categories of clinical staff who are providing clinical services on behalf of the health center.  This includes all Licensed Independent Practitioners (LIPs), Other Licensed and Certified Practitioners (OLCPs) and Other Clinical Staff (OCS) who are health center employees, contractors, volunteers and locum tenens.  As outlined in the “Related Considerations” section of “Chapter 5 – Clinical Staffing” of the HRSA Health Center Compliance Manual (Compliance Manual – Chapter 5), it is at the discretion of the health center to determine how it will assess Fitness for Duty. 

Although the HRSA Health Center Compliance Manual has not changed, both the HRSA Site Visit Protocol (Site Visit Protocol) and HRSA Credentialing and Privileging File Review Resource (Credentialing and Privileging File Review Resource) have changed.  Effective May 27, 2021, the health center’s process for verification of Fitness for Duty must demonstrate all clinical staff have the “physical and cognitive ability” so safely perform their duties.  Examples of how to easily demonstrate compliance with this requirement are outlined in the HRSA Credentialing and Privileging File Review Resource and include the following:

• Licensed Independent Practitioner – A completed statement or attestation of Fitness for Duty from the provider that is confirmed either by a training program director, a chief of staff at a hospital where privileges exist or a licensed physician who is designated by the health center.
• Other Licensed and Certified Practitioners and Other Clinical Staff – A completed statement or attestation of Fitness for Duty from the clinical staff member that is confirmed by a licensed physician designated by the health center.

As for the review process, the clinical reviewer must now provide a narrative response indicating how the health center is verifying the “physical and cognitive ability” of clinical staff.  HRSA has not provided any type of guidance indicating that an attestation cannot be utilized and is in the process of developing guidance on other methods that can be used by health centers to demonstrate compliance.  As a result, health centers should verify with their HRSA Project Officer (PO) that the current process in place for verification of Fitness for Duty is in compliance.