COMMON HRSA COMPLIANCE QUESTIONS: Clinical Staffing – NPDB Queries

The HRSA Site Visit Protocol states (Clinical Staffing, Element c. question 5.2) that a health center should complete a “query through the NPDB”. A common question regarding this topic is, “Does this include unlicensed or uncertified clinical staff (Other Clinical Staff or “OCS”)"?”.

Some health centers interpret this to mean that the health center must run National Practitioner Data Bank (NPDB) queries on their provider staff (LIPs) and some of their Other Licensed of Certified Practitioners (OLCPs) staff: RNs, LPNs, CMAs, RDs, or Pharmacists).

If you look at the first part of the compliance question cited above, you’ll see that it asks if this is done “for all clinical staff upon hire AND on a recurring basis”.

Additionally, the FTCA Credentialing and Privileging Tool states that, “The health center is required to register for the NPDB and query the NPDB for all health center staff (LIPs, OLCPs, and OCS)”.

Reporting TO the NPDB

The HRSA NPDB Guidebook states that health centers must report TO the NPDB and professional review actions, based on reasons related to professional competence or conduct, adversely affecting clinical privileges for a period longer than 30 days. Any voluntary surrender or restriction of clinical privileges while under, or to avoid, an investigation must also be reported. These types of instances must be submitted to the NPDB and appropriate State Licensing Boards within 30 days of the action for physicians and dentists while other practitioners are optional.

Why is it important to run NPDB queries on Other Clinical Staff?

Health centers will sometimes question whether it is even possible to run an NPDB query on unlicensed or uncertified staff. The answer is “yes”! Here’s an example of why it’s important to run NPDB queries on all clinical staff (even unlicensed):

A licensed physician was employed in a West Coast state and lost his MD license due to an instance of negligent malpractice. He moved to an East Coast state and applied to a health center as a Medical Assistant. The health center ran an NPDB query on him since he applied to be an unlicensed MA (“Other Clinical Staff”). Though he was no longer licensed, the finding was discovered after querying the NPDB and the health center decided not to hire him since he did not disclose this concern in the appropriate location on his employment application.

The HRSA NPDB Guidebook states that “Querying the NPDB for information on health care practitioners, entities, providers, or suppliers allows for informed decision-making. NPDB information is intended to be used in combination with information from other sources and should not be used as the sole source of verification of professional credentials.”

So, given the above information, our recommendation is to complete a query through the NPDB upon hire and on a recurring basis for all clinical staff (LIPs, OLCPs, and “Other Clinical Staff”) who are directly employed, independently contracted, or volunteers.

**Editor's Note: On February 27, 2020, HRSA clarified the HRSA Site Visit Protocol to remove the phrase, "...for NPDB-reportable provider types" from the question mentioned above. This clarifies that NPDB queries should be completed for all clinical staff (LIPs, OLCPs, and Other Clinical Staff).