Verifying Cognitive Fitness

As we have written in the past, the health center has the freedom to define how they verify “fitness for duty” for clinical staff. Fitness for duty (formerly referred to as “health fitness”) is defined by HRSA in the Health Center Program Compliance Manual as the, “ability to perform the duties of the job in a safe, secure, productive, and effective manner.”

HRSA updated the Health Center Program Site Visit Protocol in May of 2021 (Effective May 27, 2021) and added an additional question regarding fitness for duty verification. The health center must now be able to explain, “how the health center has verified fitness for duty to ensure all clinical staff have the physical and cognitive ability to safely perform their duties”.

Verifying the “physical” ability of a clinical staff member is not challenging as most health centers have systems in place for this that may include physical examinations by a provider or a self-attestation of their physical abilities.

But the new requirement of ensuring clinical staff are “cognitively” able to safely perform their duties is a little more nebulous.

During a recent HRSA training, one consultant asked the HRSA/BPHC/MSCG staff for examples of how health centers might do this – no suggestions were given.

So, here are some ideas we have for each of the various types of clinical staff:

Licensed Independent Practitioners (LIPs)

• The health center requires board certification for all LIPs upon hire (and must maintain).

• The health center requires all LIPs to submit proof of x number of Continuing Education Units (CEUs) upon hire and on a recurring basis (upon re-credentialing).

• The health center requires all OLCPs to complete a pre-employment skills exam based on the staff member’s role (Medication dosing calculation test, normal range of vital signs, injection site test, basic math test, etc.).

• Assessment of mental status by provider.

• Review of cognitive fitness as evidenced by clinical judgement and documentation in the clinician’s quarterly peer review.

Other Licensed or Certified Practitioners (OLCPs)

• The health center requires all OLCPs to submit proof of x number of Continuing Education Units (CEUs) upon hire and on a recurring basis (upon re-credentialing).

• The health center requires all OLCPs to complete a pre-employment skills exam based on the staff member’s role (Medication dosing calculation test, normal range of vital signs, injection site test, basic math test, etc.).

• Assessment of mental status by provider.

Other Clinical Staff (OCS)

• The health center requires all OCS to complete a pre-employment skills exam based on the staff member’s role (Medication dosing calculation test, normal range of vital signs, injection site test, basic math test, etc.).

• Assessment of mental status by provider.

Again, remember that it is up to the health center on how they evaluate physical and cognitive fitness for duty. However, make sure that you show that you have systems in place for verifying this fitness for duty upon hire (prior to the clinical staff member providing patient care) and on a recurring basis. Since this is a brand-new update with the upcoming HRSA Site Visit Protocol, we will keep you posted as we learn more about its real-life application.