Credentialing and Privileging of Contracted and Referral Providers Federally Qualified Health Centers (FQHCs) play a crucial role in providing comprehensive, high-quality care to underserved communities.  As outlined by the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual (HRSA Health Center Program Compliance Manual), health centers are required to provide all required primary, preventive, and enabling services, as well as any additional services, as appropriate and necessary.  One of the practices health centers utilize to maintain compliance with this requirement is through the delivery of services via formal written contracts and formal written referral arrangements.  Health centers are responsible to ensure all clinical staff delivering patient care are credentialed, privileged and competent to provide care, including contracted and referral providers.  Maintaining a thorough credentialing and privileging process for external providers is imperative to sustain standards of care and ensure patient safety.  Credentialing is the process of verifying a provider’s qualifications, experience, and licensure/board certification, whereas privileging refers to the granting of approval to the provider to perform services, activities, and procedures within an organization. The process of credentialing and privileging is critical to health centers in order to ensure compliance with regulatory requirements and safeguard the well-being of the target population being served. Chapter 5 – Clinical Staffing, of the HRSA Health Center Program Compliance Manual (Chapter 5: Clinical Staffing) outlines the requirements for credentialing and privileging of all clinical staff, including those who are directly employed and volunteer, as well as those who provide services through formal written contracts and/or formal written referral arrangements.  The responsibility of managing the credentialing and privileging process is dependent on the contractual arrangements made between the health center and the contracted/referral provider.  Below are some guidelines for maintaining compliance with the HRSA Health Center Program Requirements, as well as ensuring appropriate credentialing and privileging of external providers and the assignment of responsibility for completion of the process.

1. If the health center contracts with an individual provider that is paid as a 1099, the health center is responsible to complete the credentialing and privileging process.
2. If the health center contracts or maintains a formal written referral arrangement with a provider organization, the process is typically completed by the provider group. In this instance, the formal written contract and/or formal written referral arrangement between the health center and the contracted/referral provider must contain language that demonstrates the following:
   1. Individuals in the provider group are licensed, certified or registered as verified through a credentialing process, in accordance with applicable federal, state and local laws; and
   2. Competent and fit to perform the contracted or referred services, as assessed through a privileging process.
3. If the formal written contract or formal written referral arrangement is lacking the required language noted above, compliance with credentialing and privileging requirements can also be demonstrated by ensuring the health center has the following:
   1. The provider group’s credentialing and privileging process; or
   2. The provider group’s documentation from a nationally recognized accreditation organization.

The credentialing and privileging of external providers within an FQHC serves as a fundamental safeguard for maintaining the quality and safety of patient care, as well as minimizing risk.  Health centers should audit individual provider contracts, as well as formal written contracts and formal written referral arrangements with provider groups, to maintain continuous compliance.