Delineation of Privileges for Health Center Clinicians

HRSA requires that health centers develop and follow a “process for denying, modifying, or removing privileges based on assessments of clinical competence and/or fitness for duty” as part of the credentialing and privileging process. This requirement is often met by a health center developing a privileging list or “delineation of privileges” form and checking off the privileges granted to each clinical staff member based on their roles and license type. Because this requirement is generally left up to each health center to configure the process, I often get asked a question something like this: “Do you have a template privileging list for…[fill in the blank with the type of clinician: physician, nurse practitioner, pharmacist, registered nurse, care manager, medical assistant, etc.]?”

My reply is always the same. State practice laws for each clinician vary greatly from state to state and from specialty to specialty. In general, I recommend that health centers shouldn’t use generic templates, but rather invest time into developing a privileging list (or sometimes called a “delineation of privileges form”) for each specific role. This takes a little more time and research, but ultimately, this exercise is about reducing the risk of malpractice and improving patient safety in the care your health center provides. So that warrants some investment of time to get it right.

Though I do not generally provide template lists, I do recommend a structured process for creating a privileging list for your organization. These can be summarized in four simple steps:

• Review your state licensing board’s resources and laws

• Consult your state professional associations

• Consider your organization’s services and activities

• Have your local clinical leadership fine-tune your list

Let’s dive into each of these in greater detail.

State Licensing Board

First, go to your state’s licensing board and try to find the “scope of practice” or other related locations on the site. I’m a Registered Nurse licensed in Ohio, so I’ll use that as an example. The Ohio Board of Nursing has a “Scope of Practice” page on their website where I would begin. When I navigate to that site, it provides links to the state administrative code that spells out the relevant laws pertaining to licensed nurses in the state of Ohio. Most states probably have something similar, and so this is a great place to start: figuring out what this clinician is legally allowed or not allowed to do in your state.

State Professional Associations

Next, search the web for your state’s applicable professional association and see what guidance they have on their state's practice laws. For Ohio, it’s the Ohio chapter of the American Nurses Association. Many of the resources are only available for dues-paying members, but often they will have some helpful tools and services that are very specific to the licensed role and state laws. Also check with your local state Primary Care Association (PCA). Many state PCAs will have some helpful resources specific to health centers and your state. If they don’t, consider getting together with a few of your neighboring health centers at your next PCA conference and collaborating together on some privileging list templates. There is no need to “reinvent the wheel” when so many are needing the same resources!

Organizational Activities

Consider the relevant activities carried out at your health center and which services you anticipate this clinician will be performing. Narrow down the broad list of what this clinician could do to what your health center actually does. This sounds simple, but I am often surprised by health center privileging lists that appear to be adapted from generic hospital privileging lists. For example, I, as a registered nurse, can run a ventilator in a critical care unit. I used to do it when I worked in an ICU. But that is generally not a service that is provided in a primary care environment. (I say “generally” because I have been to very rural health centers that served as the only emergency facility for hundreds of miles, and they were sometimes required to provide emergency services until a helicopter could evacuate a patient). So, health centers should pare down the list to the actual services that will be regularly provided at the facility.

Local Clinical Leadership

Finally, it’s good to consult your health center’s highest-ranking clinician in that field employed at your organization and have them review your evolving privileging list. If it’s a delineation of privileges for Registered Nurses you're working on, and you have a “Director of Nursing” employed at your health center, have them review it and see if it’s appropriate. They often will have insights or resources that may be helpful. If there isn’t anyone already in this type of role, the previous step of consulting with a friend at a neighboring health center in your state might be the best you can do.

While working on each list, also make sure the employee’s job description aligns with (or at least doesn't conflict with) their privileges on the list. This could be an area of risk if there is a discrepancy and a patient safety concern that is related to privileges the clinician wasn't granted.

So, though we do not have an easy delineation of privileges template for each health center role to give you, our hope is that following this structured, systematic methodology for developing a list that’s appropriate for your state, your specific clinician’s role, and your health center’s services will make the process a bit easier. Contact us today if your health center would like assistance in working through this process together.

AI Disclaimer

This blog post was created 100% without the assistance of generative Artificial Intelligence (AI). It was written by a real, living (albeit fallible and quirky) human (specifically, Kyle Vath).