As outlined by Chapter 5 – Clinical Staffing, of the Health Resources and Services Administration Health Center Program Compliance Manual, health centers must utilize staff that are qualified by training and experience to perform the services within the health center’s scope of project. To demonstrate compliance, health centers must maintain operating procedures for the initial granting and renewal of privileges, which include:

• Initial hire/appointment – Verification of current clinical competence via training, education and, as available, reference reviews.
• Renewal/Reappointment – Verification of ongoing clinical competence via peer review or other comparable methods. 

Verification of competence requires health centers to clearly define the services each clinical staff member is permitted to deliver, as well as maintain documentation to support those decisions. For Licensed Independent Practitioners (LIPs), this is typically accomplished through the use of a delineation of privileges form, that clearly outlines the clinical activities the provider is authorized to perform, based on their scope of licensure and demonstrated competency. The use of a delineation of privileges form easily identifies what the provider is allowed to do, why they are qualified and the formal review and approval of privileges. 

For additional information regarding the requirements for credentialing and privileging of clinical staff, health centers should consult Chapter 5 of the HRSA Health Center Program Compliance Manual (Chapter 5: Clinical Staffing | Bureau of Primary Health Care) and HRSA Health Center Program Site Visit Protocol (Clinical Staffing | Bureau of Primary Health Care).