The answer to this question is dependent on the type of consulting services the contracted Physician will be providing.  If the Physician will be providing consulting services to staff that are delivering clinical services, then yes, the Physician must be credentialed and privileged, as the Physician is utilizing clinical judgement and making clinical recommendations regarding patient care.  Likewise, if the Physician is providing peer review services, the Physician is once again utilizing clinical judgement and evaluating the delivery of clinical care by other health center physicians; therefore, the Physician must be credentialed and privileged. Contrary to the aforementioned, if the Physician is providing consulting services, such as Operational Site Visit (OSV) Preparation or other clinical administrative services, credentialing and privileging of this Physician is not necessary, as clinical recommendations regarding the assessment and delivery of patient care are not taking place.

In accordance with “Chapter Five – Clinical Staffing” of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5), and the Clinical Staffing Section of the HRSA Site Visit Protocol (Site Visit Protocol Clinical Staffing), all clinical staff must be credentialed and privileged, as well as reappointed on a recurring basis.  HRSA defines clinical staff as health center employees, individual contractors of volunteers and includes Licensed Independent Practitioners (LIPs), Other Licensed and Certified Professionals (OLCPs) and Other Clinical Staff (OCS).  For services contracted with a provider organization, the responsibility for credentialing and privileging the provider can be conducted by the provider organization or by the health center.  In the case of an individual contractor, the responsibility for the initial credentialing, privileging and reappointment lies with the health center.