The Health Resources and Services Administration (HRSA) Health Center Program Requirements defines LIPs and OLCPs in the following manner:

• Licensed Independent Practitioner (LIP) – This category of clinical staff includes individuals who are licensed and are permitted by law and the health center to provide care and services without direction or supervision, within the scope of the individual’s license and consistent with individually granted clinical privileges. Examples of these individuals include Physicians, Dentists, Psychiatrists, Nurse Practitioners and Nurse Midwives. 

• Other Licensed or Certified Health Care Practitioner (OLCP) – This category of clinical staff includes individuals who are licensed, registered or certified, although are not permitted by law and the health center to provide care and services without supervision. Examples of these individuals include Registered Nurses, Licensed Practical Nurses, Certified Medical Assistants and Registered Dental Assistants.  

Although Nurse Practitioners and Nurse Midwives require supervision to provide services in most states, industry standard best practice demonstrates these individuals are considered LIPs due to the scope of licensure and the level of service being provided.  The approach used to categorize clinical staff as LIPs or OLCPs may vary across states, based on licensure and certification requirements, and the state scope of practice.  The health center should determine which individuals are LIPs and which individuals are OLCPs, based on state law and the organization’s policy. 

It is important to understand the requirements for Credentialing and Privileging, not only to ensure compliance with HRSA Health Center Requirements, but to ensure compliance with Federal Tort Health Claims Act (FTCA) Requirements, as well.  Health centers should follow the guidance outlined in  Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5), the HRSA Credentialing and Privileging File Review Resource (Credentialing and Privileging File Review Resource) and the FTCA Health Center Policy Manual (FTCA Policy Manual).  Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in the “Clinical Staffing” section of the most recent version (released 5/27/21) of the HRSA Site Visit Protocol (Site Visit Protocol – Clinical Staffing).