The Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual does not address the granting of Temporary Privileges. As a result, the evaluation of compliance as it relates to Temporary Privileges is not part of the Operational Site Visit (OSV) Process, although is evaluated under the requirements outlined by the Federal Tort Claims Act (FTCA).
In accordance with Program Assistance Letter (PAL) 2024-01, “Temporary Privileging of Clinical Providers by Deemed Public Health Service Employee Health Centers Impacted by Certain Declared Emergencies or Other Emergency Situations,” health centers may grant temporary privileges to clinical staff in cases where there is a declared public health emergency or “other emergency situation,” as determined by HRSA. In both cases, the health center must obtain approval by HRSA to implement temporary privileging policies and procedures.
Once approved by HRSA, the health center is required to follow a credentialing and privileging process to ensure the clinical staff member is qualified and competent to provide care. These processes must include verification and signed written findings of the following:
For detailed requirements regarding the verification process and granting of temporary privileges, health centers should follow the guidance outlined in PAL 2024-01 (PAL 2024-01 Temporary Privileges).
March 18th, 2026
10:00 AM PT // 1:00 PM ET
Regulators are no longer satisfied with documentation alone; they want evidence that your compliance program actively prevents, detects, and corrects risk. Investigators expect to see how issues are identified early, investigated thoroughly, corrected effectively, and monitored over time. Boards demand measurable insight, and leadership needs confidence that exposure is managed before it becomes a liability. The standard has shifted from activity to impact.