The health center is required to ensure all staff classified as “clinical staff” have documentation of current BLS training. As outlined in “Chapter Five, Clinical Staffing,” of the Health Resources and Services Administration (HRSA) Health Center Program Compliance Manual (Compliance Manual Chapter 5), the term clinical staff includes the following:

1. Licensed Independent Practitioner (LIP): An individual 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. Examples include, but are not limited to, Physicians, Nurse Practitioners, Physician Assistants, Dentists and Licensed Independent Social Workers. It is at the discretion of the health center to determine which individuals (including staff that may not be covered under Federal Tort Claims Act (FTCA) such as volunteers, certain part-time contractors, medical residents, and locum tenens) meet this definition based on law and the organization’s policy.
2. Other Licensed or Certified Health Care Practitioner (OLCP): An individual who is licensed, registered, or certified, although is not permitted by law to provide patient care services without direction or supervision. Examples include, but are not limited to, Registered Nurses, Licensed Practical Nurses, Certified Medical Assistants, Dental Hygienists and Registered Dental Assistants. 
3. Other Clinical Staff (OCS): An individual that provides clinical services in a state, territory or other jurisdiction that does not require licensure, registration or certification.  Examples include Medical Assistants, Dental Assistants and Community Health Workers. 

It is important for health centers to remember the requirements for BLS training are applicable to clinical staff for all services in scope. Additionally, industry standard best practice supports the documentation of BLS training for ALL staff, and not just those providing clinical services. 

Health centers should conduct a self-evaluation of compliance by answering the questions under “Element c  – Procedures for Review of Credentials” in the “Clinical Staffing” section the HRSA Health Center Program Site Visit Protocol (Site Visit Protocol Clinical Staffing), as it pertains to BLS certification.