Peer Review for OLCP and OCS

In order to meet the Health Resources and Services Administration (HRSA) and the Federal Tort Claims Act (FTCA) requirements, should we include Other Licensed and Certified Practitioners (OLCPs) and Other Clinical Staff (OCS) in a peer review policy and procedure?

Typically, peer review is completed only for Licensed Independent Practitioners (LIPs), although some high performing health centers do complete peer review for OLCPs.  HRSA does not require peer review to be completed for OLCPs and OCS, but the health center must have some type of method in place for verifying competency and evaluating performance on an ongoing basis.  This can be accomplished through the completion of annual competencies and what is often considered chart review.  In the case of OLCPs and OCS, the tool being utilized to conduct the chart review is tailored to the specific skills for the scope of licensure (if a licensure, registration or certification is applicable), as well as the job responsibilities outlined in the job description.  

The health center is not required to include OLCPs and OCS in the Peer Review Policy and Procedure for LIPs, although the health center should maintain a separate document(s) outlining the process utilized to evaluate the performance/competency of these categories of clinical staff. 

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