Although Medical Residents provide care under the supervision of a preceptor, they are often considered Licensed Independent Practitioners (LIPs) due to the scope of licensure and privileges; therefore, they are not considered OLCPs or OCS.  

The responsibility of the health center is to maintain a process that ensures medical residents are appropriately qualified and supervised while providing care, in order to maintain high standards of patient safety and quality of care. In the case of Medical Residents, the health center usually maintains a formal, written contract with the residency program, which outlines the specific responsibilities for credentialing and privileging of Medical Residents.  

Page 30, letter e, of the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual (Chapter 5: Clinical Staffing | Health Center Compliance Manual) states, “If the health center has contracts with provider organizations (for example, group practices, locum tenens staffing agencies, training programs) or formal, written referral agreements with other provider organizations that provide services within its scope of project, the health center ensures that such providers are 1) 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.  Additionally, the footnote attached to this statement states, “This may be done, for example, through provisions in contracts and cooperative arrangements with such organizations or health center review of the organizations’ credentialing and privileging processes.”