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The answer is dependent on whether or not the Medical Assistant maintains any type of license, certification, or registration. 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 who are providing direct patient care in a state, territory, or other jurisdiction that does not require licensure, registration, or certification. Typically, clinical staff members in this category are Medical Assistants, Dental Assistants, Health Educators, and Community Health Workers.
If the Medical Assistant maintains any type of license, certification, or registration, they fall under the category of Other Licensed or Certified Practitioners (OLCPs). This category of staff includes clinical staff providing direct patient care who are licensed, registered, or certified, although they are not permitted by law to provide patient care services without direction or supervision. Typically, clinical staff members in this category are Registered Nurses, Licensed Practical Nurses, Certified Medical Assistants, and Registered Dental Assistants.
Regardless of whether the Medical Assistant is an OLCP or an OCS, the health center must have documented procedures in place for credentialing and privileging/competency validation upon initial hire, and on a recurring basis, which is typically a minimum of every two years.
Health centers should follow the guidance outlined in Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5) and the HRSA Health Center Program Site Visit Protocol: Examples of Credentialing and Privileging Documentation (Examples of Credentialing and Privileging Documentation). Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in the Clinical Staffing section of the HRSA Health Center Program Site Visit Protocol (Site Visit Protocol Clinical Staffing).