Upon the release of the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual, health centers were no longer required to obtain approval by the Board of Directors for privileging of Licensed Independent Practitioners (LIPs).  As noted in the “Related Considerations” section of “Chapter 5 – Clinical Staffing” of the HRSA Health Center Program Compliance Manual (Chapter 5: Clinical Staffing | Related Considerations), health centers have discretion with respect to decision-making and are responsible to determine who has approval authority for credentialing and privileging of clinical staff.  Although HRSA does not require a specific individual to approve clinical privileges, HRSA does require health centers to maintain a credentialing and privileging process that is documented, consistently followed, and includes the formal granting of privileges.  Consequently, the health center’s Credentialing and Privileging Policy/Procedure must, at a minimum, address the following:

1. Who is authorized to grant privileges – This may be a number of different individuals, including the Chief Medical Officer, Chief Executive Officer or the health center’s Board of Directors. 
2. How recommendations are reviewed – Clinical leadership is typically responsible to review and recommend granting of privileges, prior to final approval, in order to confirm the initial review of qualifications and competency.   
3. Which signatures are required to document the privileging decision – These signatures should be noted on the applicant’s Delineation of Privileges Form and/or on a separate form/letter that is provided to the applicant. 

Additional information on credentialing and privileging can be found by reviewing (Chapter 5: Clinical Staffing | HRSA Compliance Manual) and (Clinical Staffing | HRSA Site Visit Protocol).