Documenting Contracted Clinical Staff on HRSA Form 5A

I have been increasingly asked:

"If our FQHC has a locums contract, we assume we enter this on HRSA’s Form 5A in Column II under 'General Primary Medical Care' services. If the locum provider also provides other required services (like OB/GYN, voluntary family planning, screenings, after-hours coverage, well-child care, case management, etc.), should our health center also document Column II for every single service they provide (marking Column II for 'General Primary Medical Care’ and 'Diagnostic Lab Services', 'Screening Services', 'After Hours Emergency Services', etc.) or is 'General Primary Medical Care' considered the umbrella service and all the other services are considered just part of providing good primary medical care (and not required to mark every service on Form 5A)?"

Throughout my years as a contracted HRSA Operational Site Visits (OSV) reviewer, I have had federal staff (as well as my fellow clinical reviewers) give me conflicting guidance. So, when asked several weeks ago again, I put together this question and submitted it via the BPHC Contact Form. The BPHC Answers team responded and provided the following guidance on January 6, 2026, 11:25am ET):

"The appropriate box should be checked in each service category (Column I, II, and III) for each service provided. A locums contract would be considered like any other contractor. Although the locum tenens staffing agency may only be periodically used, it is still a method in which the health center provides the services, and should be recorded accordingly in Form 5A. Please review our Column Descriptors document for more information on how to record items in Form 5A."

Practical Application

So practically speaking, if a health center indicates they employ a contracted clinical staff member (I am defining “clinical staff” as HRSA defines them in the clinical staffing requirements as being staff that are credentialed: “LIPs, OLCPs, and Other Clinical Staff”), I am going to ask the health center leadership to clearly define which services they are providing in the Form 5A Service Descriptors document and any services they provide, my recommendation will be for them to mark each of those services in Column II.

I will then review the contract associated with the locum clinical staff member and recommend that the contract should have language spelling out each of those services provided in the contract itself.

Here’s a very practical example: A health center has a locum provider (LIP) who is a family practice physician. Upon asking them what services they provide, the health center notes that they provide:

• General primary care services (General Primary Medical Care)

• Ordering diagnostic labs (Diagnostic Laboratory)

• Ordering diagnostic radiologic images (Diagnostic Radiology)

• Complete Pap smears (Screenings)

• The take after-hours call (Coverage for Emergencies During and After Hours)

• Provide family planning services (Voluntary Family Planning)

• Order age-appropriate vaccines (Immunizations)

• Provide well-child visits (Well Child Services)

• Complete Pap smears, pelvic exams, and breast exams (Gynecological Care)

• Provide prenatal OB care (OB-Prenatal Care)

• Provide postpartum OB care (OB-Postpartum Care)

• Provide tobacco cessation teaching (Health Education)

• Provide acupuncture services (Complementary and Alternative Medicine)

So, in this example, my recommendation is to mark this locum provider in Column II under the following Form 5A services: General Primary Medical Care, Diagnostic Laboratory, Diagnostic Radiology, Screenings, Coverage for Emergencies During and After Hours, Voluntary Family Planning, Immunizations, Well Child Services, Gynecological Care, OB-Prenatal Care, OB-Postpartum Care, Health Education, and Complementary and Alternative Medicine.

I am also going to review their contract for these services and recommend that their contract has language similar to the following: “Services provided will be General Primary Medical Care, Diagnostic Laboratory, Diagnostic Radiology, Screenings, Coverage for Emergencies During and After Hours, Voluntary Family Planning, Immunizations, Well Child Services, Gynecological Care, OB-Prenatal Care, OB-Postpartum Care, Health Education, and Complementary and Alternative Medicine."

Key Take-Aways

If you employ contracted clinical staff (LIPs, OLCPs, or Other Clinical Staff) who are either individually contracted (1099) or organizationally contracted (through a locum tenens agency, hospital system, or other organization), make sure to review your HRSA Form 5A to assess whether your documentation is aligned with this clarified recommendation. Also, review any associated contracts and ensure all services marked on Form 5A as being provided by these contracted clinical staff are listed in the contract as services provided.

If you need help, please schedule a complimentary Form 5A evaluation with our compliance experts today! We’re here to support you and your team!