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Is an after-hours test call still performed during a virtual Operational Site Visit (vOSV)?
As outlined by 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). The “Related Considerations” section of “Chapter 5 – Clinical Staffing” of the HRSA Compliance Manual (Chapter 5: Clinical Staffing) indicates it is at the discretion of the health center to determine how Fitness for Duty will be verified, although one of the easiest ways is through the use of a confirmed statement/attestation.
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; therefore, if an attestation is being utilized, files for all clinical staff should contain this document.
Prior to the release of the updated HRSA Site Visit Protocol on May 26, 2022, the use of a confirmed statement/attestation required signature by a designated licensed “physician” of the health center. The Examples of Credentialing and Privileging Documentation (Examples of Credentialing and Privileging Documentation), formerly known as the “Credentialing and Privileging File Review Resource,” now states the use of an attestation can be confirmed by a designated licensed “provider” of the health center. As a result, the attestation can be signed by a designated licensed physician or mid-level provider.
It is important to remember that verification of Fitness for Duty must ensure all clinical staff have the “physical and cognitive” ability to safely perform their duties. The HRSA Site Visit Protocol (Clinical Staffing | 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. Including this verbiage on the attestation will ensure compliance with the Fitness for Duty requirement.