Do Fitness for Duty forms need to be completed at reappointment?

Does the Health Resources and Services Administration (HRSA) require Fitness for Duty Forms to be completed at the time of reappointment?

Chapter Five – Clinical Staffing, of the HRSA Health Center Program Compliance Manual requires verification of Fitness for Duty upon initial hire and at the time of reappointment for all clinical staff, including Licensed Independent Practitioners (LIPs), Other Licensed and Certified Practitioners (OLCPs) and Other Clinical Staff (OCS). 

While HRSA does not specifically require the use of a Fitness for Duty Form to demonstrate verification of Fitness for Duty, the health center must have a process in place to ensure all clinical staff are competent and fit to perform their duties and have the physical and cognitive ability to perform their responsibilities in a safe and efficient manner.  

Although many health centers choose to demonstrate verification of Fitness for Duty for both initial hire and reappointment through the use of a Fitness for Duty Attestation Form, it is at the discretion of the health center to determine how Fitness for Duty will be verified. If using a Fitness for Duty Attestation Form, the health center must ensure the attestation is signed by the applicant, as well as a designated provider. Additionally, the health center must ensure the process used to verify Fitness for Duty is clearly outlined in the health center’s written Credentialing and Privileging Policies and Procedures.  

Additional resources regarding the requirements for Fitness for Duty can be found by clicking on the following: Compliance Manual Chapter 5 and Examples of Credentialing and Privileging Documentation.

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