Yes, health centers can continue to verify Fitness for Duty using a self-attestation, although there are best practices that should be put into place when using this method.  For the purposes of the Health Resources and Services Administration (HRSA) Compliance Manual, Fitness for Duty, formerly known as “health fitness,” is defined as the ability of the clinical staff member to perform the required duties in a safe, secure, productive and effective manner (Fitness for Duty).  

Fitness for Duty is a privileging activity that is required for all categories of clinical staff upon initial hire and reappointment.  This includes Licensed Independent Practitioners (LIPs), Other Licensed and Certified Practitioners (OLCPs) and Other Clinical Staff (OCS) who are employees, contractors, volunteers, and locum tenens.  The “Related Considerations” section of Chapter 5 – Clinical Staffing of the HRSA Health Center Compliance Manual (Chapter 5 – Clinical Staffing), states the health center determines the methodology used to assess clinical competence and Fitness for Duty for clinical staff members. 

Although the HRSA Health Center Compliance Manual has not been revised, the HRSA Site Visit Protocol, released May 26, 2022, has been updated (Clinical Staffing – Site Visit Protocol).  Additionally, the Examples of Credentialing and Privileging Documentation (Examples of Credentialing and Privileging Documentation), formerly referred to as the “Credentialing and Privileging File Review Resource,” has been updated to provide health centers with examples of how to demonstrate compliance with credentialing and privileging requirements.  

As outlined by the HRSA Health Center Site Visit Protocol and Examples of Credentialing and Privileging Documentation, Fitness for Duty must verify all clinical staff have the “physical and cognitive” ability to safely perform their duties.  The example provided is 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 provider 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 provider designated by the health center. 

It is important to note the individual confirming the attestation no longer needs to be a licensed physician and can be a licensed provider.  The HRSA Site Visit Protocol requires the clinical reviewer to document a narrative response stating how the health center is verifying the “physical and cognitive ability” of all clinical staff.  Outside of the use of an attestation form, HRSA has not provided guidance on other methods that meet the requirement.