The answer to this question depends on the credentials of the individual providing the service.  In accordance with the Health Resources and Services Administration (HRSA) Requirements, clinical staff can fall under one of three categories:

• Licensed Independent Practitioner (LIP) – This category includes individuals who are licensed and are permitted by law and the organization to provide care and services without direction or supervision, within the scope of the individual’s license and consistent with individually granted clinical privileges.
• Other Licensed or Certified Health Care Practitioner (OLCP) – This category includes individuals who are licensed, registered or certified, although are not permitted by law and the organization to provide care and services without supervision.
• Other Clinical Staff (OCS) – This category of staff includes individuals that provide services in a state, territory or other jurisdiction that does not require licensure, registration, or certification. 

OCS is a new category of staff that was developed with the release of the HRSA Compliance Manual.  (HRSA Compliance Manual).  In most cases, Recovery Peer Support Staff fall under this category, as they are not typically licensed or certified and are providing peer support services to health center patients based on their own successful recovery. It is important to remember the health center must have documented procedures in place for credentialing and validating competency for this category of staff.  Resources for the development of core competencies for Recovery Peer Support Staff can be found at (Core Competencies for Peer Workers in Behavioral Health Services (samhsa.gov)).

Health centers should follow the guidance outlined in  Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5) and the HRSA Credentialing and Privileging File Review Resource (Credentialing and Privileging File Review Resource).  Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in the “Clinical Staffing” section of the HRSA Site Visit Protocol (Site Visit Protocol Clinical Staffing), as it pertains to OCS.