The Health Resources and Services Administration (HRSA) Health Center Program Requirements define LIPs and OLCPs in the following manner:
As outlined in the Footnotes Section of the HRSA Health Center Program Site Visit Protocol: Examples of Credentialing and Privileging Documentation (HRSA Examples of Credentialing and Privileging Documentation), various states may have different scope of practice, as well as licensure and certification requirements, that may impact how the health center categorizes clinical staff. The key to determining whether a Licensed Clinical Social Worker (LCSW) is an LIP or an OLCP is to consider state law, and whether the individual is licensed and can practice independently. Additionally, the health center should ensure the organization’s Credentialing and Privileging Policy/Procedures are reflective of current practice and accurately reflect the process for credentialing and privileging the various categories of 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.