Other Clinical Staff (OCS) is a new category of staff that was developed with the release of the Health Resources and Services Administration (HRSA) Compliance Manual (HRSA Compliance Manual).  OCS includes clinical staff members that provide services in a state, territory or other jurisdiction that does not require licensure, registration, or certification.  Examples of OCS include medical assistants, dental assistants, and community health workers.  If a health center has this category of staff, it must have documented procedures in place for credentialing and privileging/competency validation, although it is at the discretion of the center to determine which aspects of the credentialing process apply.  Industry standard best practices support the verification of competency for OCS upon initial hire, annually thereafter, and as necessary for a decline in performance.  If a health center does not utilize this category of staff, there is no requirement to have documented procedures. 

Health centers should follow the guidance outlined in Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5) and the HRSA Credentialing and Privileging File Review Resource (Credentialing and Privileging File Review Resource).  Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in the “Clinical Staffing” section of the HRSA Site Visit Protocol (Site Visit Protocol Clinical Staffing), as it pertains to OCS.