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Do Clinical Assistants (Non-Licensed Staff) who perform symptom screening have to be credentialed as Other Clinical Support Staff?
The answer to this question requires clarification on a number of different levels and will also include some assumptions, as the term “Clinical Assistant” is not one frequently utilized by the Health Resources and Services Administration (HRSA). Although the Clinical Assistant may not be licensed, if they are certified or registered in any manner, they are required to be credentialed and privileged as an Other Licensed or Certified Practitioner (OLCP). If the Clinical Assistant is not certified or registered in any manner, they are required to be credentialed and privileged as Other Clinical Staff (OCS).
OCS is a category of clinical staff members that provide clinical services in a state, territory or other jurisdiction where licensure, certification or registration is not required. Typically, clinical staff members in this category are Medical Assistants, Dental Assistants, Health Educators and Community Health Workers. In this case, the term Clinical Assistant sounds similar to the role of a Medical Assistant. Even though the Clinical Assistant is only performing symptom screening, they are considered what HRSA defines as “Clinical Staff”, which includes Licensed Independent Practitioners (LIPs), Other Licensed and Certified Practitioners (OLCPs) and Other Clinical Staff (OCS) who are employees, individual contractors, and volunteers.
Health centers should follow the guidance outlined in Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5) and the Health Center Program Site Visit Protocol: Examples of Credentialing and Privileging Documentation (HRSA 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 Site Visit Protocol (Clinical Staffing), as it pertains to OCS.