As outlined by the Health Resources and Services Administration (HRSA) Health Center Program Requirements, clinical staff fall into one of the following three categories:

• 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.
• 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.
• Other Clinical Staff (OCS) – This category of clinical staff includes individuals that provide services in a state, territory or other jurisdiction that does not require licensure, registration, or certification.  

Typically, a Pharmacist is credentialed and privileged as an LIP, although the methodology utilized by the health center to categorize providers as LIPs or OLCPs may vary by state, based on licensure and certification requirements, as well as the scope of practice approved by the state. In states where a Pharmacist is technically considered an OLCP and requires supervision to provide services, the health center may decide to credential and privilege a Pharmacist as an LIP.  This aligns with industry standard best practice, due to the level of service being provided by the Pharmacist.  

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 most recent version (released 5/27/21) of the HRSA Site Visit Protocol (Site Visit Protocol – Clinical Staffing).