HRSA NPDB Query Requirements for Health Centers

The HRSA Site Visit Protocol (SVP) requires health centers to query the National Practitioner Data Bank (NPDB) as part of credentialing. A frequent question we receive is: “Which staff must we query — and does that include unlicensed or uncertified clinical staff (“Other Clinical Staff,” or OCS)?” This post walks through HRSA's evolving guidance, the difference between querying and reporting, and why we recommend querying all clinical staff.

What HRSA Requires

The HRSA Site Visit Protocol (Chapter 3: Clinical Staffing, Element c, question 5.2) asks whether the health center's credentialing procedures require a “query through the NPDB” for “all clinical staff (LIPs, OLCPs, and other clinical staff) upon hire AND on a recurring basis.”

The FTCA Credentialing and Privileging Tool reinforces this, stating: “The health center is required to register for the NPDB and query the NPDB for all health center staff (LIPs, OLCPs, and OCS).”

HRSA's Examples of Credentialing and Privileging Documentation resource further clarifies who falls under NPDB scope:

“The NPDB's subjects include all health care practitioners, providers, and suppliers in the United States. Health care practitioners include any individual who is licensed or otherwise authorized by a state to provide health care services (or any individual who, without authority, holds himself or herself out to be so licensed or authorized). Therefore, anyone involved in the delivery or provision of health care services may be reported to the NPDB. For more information, visit Examples of Health Care Practitioners.”

The Evolving SVP Language

HRSA updated the SVP on February 27, 2020. The one substantive change was to question 5.2 above: HRSA removed the phrase “…for NPDB-reportable provider types” from the end of the question. Most reviewers and consultants interpreted this as a clarification — namely, that NPDB queries should be performed for all clinical staff (LIPs, OLCPs, and OCS), not only those whose conduct is itself reportable to NPDB.

Then, on November 20, 2025, HRSA reversed that change and restored the “…for NPDB-reportable provider types” language to the SVP.

Our recommendation has not changed: query the NPDB for all clinical staff (LIPs, OLCPs, and OCS) upon hire and on a recurring basis (every two years for FTCA-deemed health centers), whether directly employed, individually contracted, or volunteers.

Querying vs. Reporting

According to the HRSA NPDB Guidebook, health centers must report professional review actions — based on professional competence or conduct — that adversely affect clinical privileges for more than 30 days. Any voluntary surrender or restriction of clinical privileges while under, or to avoid, an investigation must also be reported. Reports must be submitted to the NPDB and the appropriate State Licensing Boards within 30 days for physicians and dentists; reporting for other practitioners is optional.

Why Query Other Clinical Staff?

Health centers sometimes ask whether it is even possible to run an NPDB query on unlicensed or uncertified staff. The answer is yes — and here is a real-world example of why it matters:

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. Because the health center ran NPDB queries on all clinical staff, including unlicensed MAs (OCS), the prior license action surfaced. The health center declined to hire him after he failed to disclose the issue on his employment application.

The HRSA NPDB Guidebook notes: “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.”

Recommendations

• Visit the HRSA Site Visit Protocol page and the NPDB Health Center page for current guidance.

• Watch HRSA's presentation on NPDB requirements for community health centers (2021).

• Reference the HRSA Compliance Manual to support continuous HRSA compliance.

• Before your next HRSA Operational Site Visit, conduct a mock site visit — internally or with a trusted consultant like RegLantern — to confirm your credentialing and privileging processes are correct and up-to-date.

Bottom Line

Complete a query through the NPDB upon hire and on a recurring basis (every two years for FTCA-deemed health centers) for all clinical staff — LIPs, OLCPs, and Other Clinical Staff — who are directly employed, individually contracted, or volunteers.

Reviewed: April 30, 2026