PIN 2004-24, September 24, 2004
Federal Tort Claims Act Coverage of Free Clinic
Volunteer Health Care Professionals
APPLICATION
AND APPLICATION INSTRUCTIONS
OMB #0915-0293 Exp. 03/31/2005
For a printer-friendly version of this application, download the PDF File and PDF file of the cover letter. |
DOCUMENT NUMBER: 2004-24
DOCUMENT TITLE: Federal Tort
Claims Act Coverage of Free Clinic Volunteer
Health Care Professionals
TO: Free Clinics; All interested parties
This Program Information Notice (PIN) provides detailed information regarding the implementation of the Free Clinics Federal Tort Claims Act (FTCA) Medical Malpractice Program (the Program) as described in Section 194 of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Specifically, this PIN provides information on:
If you have questions regarding this Program or the application process described in this PIN, please contact the Free Clinics FTCA Program at 301-594-0818 or via email: FreeClinicsFTCA@hrsa.gov
/s
Sam S. Shekar, M.D., M.P.H.
Assistant Surgeon General and
Associate Administrator for Primary Health Care
I. PURPOSE
This Program Information Notice (PIN) provides detailed information regarding
the implementation of the Free Clinics Federal Tort Claims Act (FTCA) Medical
Malpractice Program (the Program) as described in Section 194 of the Health
Insurance Portability and Accountability Act of 1996 (HIPAA). This PIN provides
information on:
A free clinic is a health care facility operated by a nonprofit private entity that:
A volunteer free clinic health professional:
An example of a FTCA covered offsite program or event carried out by a free clinic is a health fair sponsored by the free clinic. If a free clinic is unsure whether an offsite program or event is covered by FTCA, the free clinic may apply to the HRSA Associate Administrator for Primary Care (through the free clinics FTCA Program) for a determination of coverage. The request must sufficiently detail:
A. Credentialing and Privileging
Credentialing and Privileging Definitions
HHS will deem a volunteer free clinic health care professional to be a federal employee for purposes of FTCA coverage for medical malpractice claims if specific credentialing and privileging requirements are met. For the purposes of the Program:
Free Clinics can satisfy many of the credentialing and privileging requirements by utilizing primary and secondary source verification. For the purposes of the Program:
Only volunteer health care professionals who are licensed or certified are eligible for FTCA deemed status (see Section III). Licensed or certified health care practitioners can be divided into two categories:
Credentialing and
Privileging Requirements
The free clinic
must determine whether each volunteer health care professional meets the definition
of a LIP or other licensed or certified health care practitioner based on State
law and the free clinic’s policies. Further, the free clinic must assure that
these licensed or certified health care practitioners are credentialed and privileged.
Credentialing and privileging requirements differ depending on whether the volunteer
health care professional is a LIP or other licensed or certified health care
practitioner.
Initial Credentialing of LIPs
The initial credentialing of LIPs should include:
1) Primary source verification of:
2) Secondary source verification of:
3) Querying the National Practitioner Data Bank (NPDB), as applicable (If the free clinic is ineligible to query the NPDB, it should have the LIP provide the results of a self-query).
The free clinic should complete the credentialing process for the LIP prior to the practitioner providing patient care services at the free clinic.
Initial Privileging
of LIPs
The initial privileging
of a LIP involves the assessment of his/her current competence in the specific
scope or content of patient care services he/she is to provide at the free clinic.
The free clinic should assure that the specific assessment procedures utilized
are appropriate for the LIP’s specialty, breadth of clinical services to be
provided to patients, and accessibility to ancillary and tertiary medical practitioners.
A free clinic could assess a LIP’s competence by any combination of: 2) Documentation
of first hand, one-on-one review of the LIP’s competence in particular procedures
or management protocols by a supervising clinician who possesses privileges
in the particular procedures or management protocols; and/or 3) Direct proctoring
of the LIP in particular procedures or management protocols by a qualified clinician
possessing a degree of expertise in the particular procedures or protocols beyond
the level of expertise of most primary care providers.
Approval Authority
for Initial LIP Credentialing and Privileging
The free clinic’s
governing board should state in writing its determination that a LIP meets credentialing
and privileging requirements. This determination can be based on the recommendation
of the Medical Director or the combined recommendation of medical staff (including
the Medical Director) and the Executive Director. Alternatively, the governing
board may delegate this responsibility (via resolution or bylaws) to an appropriate
individual to be implemented based on approved policies and procedures (including
methods to assess compliance with these policies and procedures).
Temporary Privileging
Requirements for LIPs
The free
clinic should strive to complete the privileging process prior to the LIP being
allowed to provide patient care services. However, if the free clinic has established
temporary privileging policies and procedures, it can grant temporary privileges
to a LIP:
1) To meet important patient care needs for a limited period of time [3](requires verification, which can be done by phone, of the provider’s current licensure and current competence in the specific scope or content of patient care services he/she is to provide at the free clinic); or
2) To issue privileges for new volunteer free clinic health care professionals for a period not to exceed 120 days, requiring verification of:
Free clinics should not provide temporary privileges for situations in which:
In these situations, the free clinic must require that the LIP cease providing patient care in the free clinic until the privileging process is completed.
Initial Credentialing of Other Licensed or Certified Practitioners
The initial credentialing of other licensed or certified practitioners should include:
1) Primary source verification current licensure, registration, or certification;
2) Secondary source verification of:
3) Querying the NPDB, as applicable (If the free clinic is ineligible to query the NPDB, it must have the licensed or certified practitioner provide the results of a self-query).
A free clinic also may choose to credential other licensed or certified health care practitioners via similar requirements utilized for LIPs. Free clinics must complete the credentialing process for other licensed or certified health care practitioners prior to the practitioners providing patient care services at the free clinic.
Initial Privileging of Other Licensed or Certified Practitioners
The initial privileging of an other licensed or certified practitioner involves the assessment of his/her current competence in the specific scope or content of patient care services he/she is to provide at the free clinic. A free clinic can assess current competency through an orientation process during which a supervisor evaluates the practitioner’s clinical qualifications and performance based on his/her job description. Approval Authority for Initial Credentialing and Privileging of Other Licensed or Certified Health Care PractitionersThe Executive Director should state in writing his/her determination that an other licensed or certified health care practitioner meets credentialing and privileging requirements. This determination should be based on the Medical Director’s review of credentialing information and the supervisor’s evaluation of the practitioner’s clinical qualifications and performance.
Alternatively, the Executive Director may delegate this responsibility (via resolution or bylaws) to an appropriate individual to be implemented based on approved policies and procedures (including methods to assess compliance with these policies and procedures).
Reassessment of the Credentials and Privileges of LIPs and Other Licensed or Certified Health Care PractitionersThe free clinic should reassess the credentials and privileges of LIPs and other licensed or certified health care practitioners at least every 2 years. Renewed credentialing and privileging processes should include:
1) Primary source verification of current licensure, registration or certification;
2) Secondary source verification of:
3) An assessment of current competency to include:
4) Querying the NPDB, as applicable.
The free clinic should notify LIPs and other licensed or certified health care practitioners that they have successfully completed the renewed credentialing and privileging processes in the same manner used for initial credentialing and privileging.
The free clinic should have an appeal process that a LIP can undertake if the free clinic decides to discontinue or deny his/her clinical privileges. An appeal process is optional for other licensed or certified health care practitioners.
B. Patient Notice of Limited Legal Liability of FTCA Deemed Health Care ProfessionalsA FTCA deemed volunteer free clinic health care professional or the free clinic must provide each patient with written notification of the limited liability of the health care professional pursuant to FTCA. The volunteer health care professional and/or free clinic can satisfy this statutory requirement by having each patient review a notification document prior to the first encounter between the patient and the health care professional. It is preferable that the health care practitioner or free clinic obtain the patient’s signature on the notice and include the notice in the patient’s medical record. If the volunteer health care professional is providing emergency care, the health care professional or free clinic may provide the written notice as soon thereafter as is practicable. The health care professional or free clinic should provide the notice to a parent or legal guardian when the patient lacks legal responsibility for his/her care under the law of the State where care is provided.
A sample patient notice
can be found in Appendix C. Free clinics also may choose to develop their own
patient notice form. The free clinic’s form must at a minimum address all of
the requirements listed in the sample.
Upon receipt of the claim, HHS will determine whether FTCA medical malpractice coverage applies to the particular claim if the alleged act or omission giving rise to the claim:
If HHS denies the claim or HHS action is pending after 6 months, the claimant can file suit against the United States. FTCA medical malpractice cases are heard in federal district court without a jury and are defended by the Department of Justice with the assistance of the Office of General Counsel, Department of Health and Human Services. No punitive damages are allowed.
A. Overview
A free clinic must sponsor each volunteer free clinic health care professional that participates in the Program. A free clinic can sponsor volunteer free clinic health care professionals by submitting a FTCA deeming application to the HHS Secretary through the Free Clinics FTCA Program. This application is attached (see Appendices). The free clinic can download additional deeming applications from the web at http://www.bphc.hrsa.gov/freeclinicsftca/application.htm. Free clinics should submit
Free Clinics FTCA Program
Division of Clinical
Quality
Bureau of Primary
Health Care, HRSA
4350 East West Highway
Bethesda, MD 20814
FreeClincsFTCA@hrsa.gov (for electronic submissions)
Failure to submit any of the requested information will render the application incomplete. The application will not be considered until the missing information is provided.
B. Original Deeming Application
A free clinic may submit an original FTCA deeming application at any time after the effective date of this notice. The original deeming application requires information fulfilling statutory and programmatic requirements, including (see Appendix A):
HRSA’s Associate Administrator for Primary Care will make final decisions regarding FTCA deeming of volunteer free clinic health care professionals within 30 days of receipt of a complete application. The HRSA Associate Administrator will provide the free clinic with written notification of the effective date of its volunteer health care professionals’ FTCA deemed status. Original deeming will be valid through the remainder of the calendar year.
C. Annual Renewal Deeming Application
The free clinic subsequently can sponsor volunteer health care professionals annually by submitting a FTCA annual renewal application. The original deeming letter from the HRSA Associate Administrator will list the due date for annual renewal applications that will stagger free clinics’ application submission dates.
The HRSA Associate Administrator will make final decisions regarding FTCA deeming renewal of volunteer free clinic health care professionals. If the renewal application is approved, in December, the HRSA Associate Administrator will provide the free clinic with written notification of its volunteer health care professionals’ FTCA deemed status that will be valid through the subsequent calendar year.
D. Supplemental Deeming Application
If a free clinic desires FTCA coverage of additional volunteer free clinic health care professionals prior to the due date for the annual renewal application, the free clinic must submit a supplemental deeming application (see Appendix B) that contains:
Supplemental deeming
will be valid through the remainder of the calendar year.
The Program provides protection only from allegations of medical negligence for volunteer free clinic health professionals as defined in Section III of this PIN. Other free clinic staff and the free clinic corporation are not covered under FTCA. Additionally, the Program does not provide protection against perils normally protected by general liability and directors and officers’ insurance policies. Free clinics should consult with their insurance agents to determine their needs for protection beyond the Program.
Appendix A
Deeming Application – Original or Annual Renewal
A.1 – Application
Form
A.2 - Application
Checklist
Appendix B
Deeming Application – Supplemental
B.1 – Application
Form
B.2 –Application
Checklist
Appendix C
Sample Patient Notice of Limited Liability of FTCA Deemed Volunteer free Clinic
Health Professionals
Appendix A.1
FREE CLINICS FEDERAL TORT CLAIMS ACT (FTCA) PROGRAM SECTION I –SPONSORING FREE CLINIC |
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Free Clinic FTCA Number: (Leave blank if original deeming application) Free Clinic Corporate Name: (If there has been a legal name change since the last application submission, please attach the appropriate state document indicating the change.) Corporate Address: |
SECTION
II –FREE CLINIC SITES |
Free Clinic Site - main or additional (circle one): Name:Address: Telephone Number: Fax Number: E-mail: Days/Hours of Operations: Executive Director: Telephone No.: Medical Director: Telephone No.: |
Free Clinic Site - main or additional (circle one): Name:Address: Telephone Number: Fax Number: E-mail: Days/Hours of Operations: Executive Director: Telephone No.: Medical Director: Telephone No.: |
Please make additional copies of this page to list any additional sites.
SECTION
III – CREDENTIALING AND PRIVILEGING SYSTEMS Please answer YES or NO to the following questions by marking in the appropriate box. “NO” answers require an explanation in Section V. |
||
---|---|---|
Item |
Yes |
No |
A. The free clinic periodically verifies licensure, certification and/or registration of each volunteer health care professional according to the instructions in PIN 2004 - xx. | ||
B. The free clinic has a copy of each volunteer health care professional's current license, certification, and/or registration on file at the free clinic. | ||
C. The free clinic periodically verifies board eligibility or certification for each volunteer health care professional, when applicable, according to instructions in PIN 2004-xx. | ||
D. The free clinic utilizes peer review activities when it periodically privileges volunteer health care professionals according to the instructions in PIN 2004-xx. | ||
E. During the credentialing processes, the free clinic requires each volunteer health care practitioner to submit a personal statement or other evidence of fitness to perform expected health care duties according to the instructions in PIN 2004-xx. | ||
F. The free clinic has a copy of each volunteer health care professional’s hospital privileges, when applicable, on file. | ||
G. The free clinic annually reviews each volunteer health care professional's history of prior and current FTCA medical malpractice claims. | ||
H. During the credentialing process of volunteer health care professionals, the free clinic queries the National Practitioner Data Bank according to the instructions in PIN 2004-xx. |
SECTION
IV – RISK MANAGEMENT SYSTEMS Please answer YES or NO to the following questions by marking in the appropriate box. “NO” answers require an explanation in Section V. |
||
---|---|---|
Item |
Yes | No |
A. The free clinic has policies and procedures in place for the provision of appropriate supervision and back-up of clinical staff | ||
B. The free clinic maintains a medical record for every patient receiving care from its organization. | ||
C. The free clinic has policies and procedures that address triage, walk-in patients and telephone triage. | ||
D. The free clinic has protocols that define appropriate treatment and diagnostic procedures for selected medical conditions based on current standard of care. | ||
E. The free clinic has a tracking system for patients who miss appointments or require follow-up of referrals, hospitalization, x-rays, or laboratory results. |
||
F. The free clinic periodically reviews patients’ medical records to determine quality, completeness and legibility. | ||
G. The free clinic has a written, current quality assurance plan (please attach a copy). | ||
H. The free clinic has regular, periodic meetings to review and assess quality assurance issues. |
||
I. The free clinic considers findings from its peer review activities when reviewing and/or revising its quality assurance plan. | ||
J. The free clinic utilizes quality assurance finding to modify policies to improve patient care. | ||
K. The free clinic’s volunteer health care professionals annually participate in risk management continuing education activities. | ||
L. The free clinic has assured that each volunteer health care professional has a copy of PIN 2004-xx and that his/her questions regarding FTCA medical malpractice coverage have been addressed. |
SECTION
V – ADDITIONAL INFORMATION REGARDING CREDENTIALING, PRIVILEGING, AND RISK
MANAGEMENT SYSTEMS Explanations
of each “No” answer from Sections III & IV. |
---|
Please attach additional pages, if needed.
SECTION VI - FREE CLINIC VOLUNTEER HEALTH CARE PROFESSIONALS List of all volunteer free clinic health care professionals that the free clinic wants to sponsor for FTCA deemed status. |
||||||||
---|---|---|---|---|---|---|---|---|
Name |
Professional designation(e.g., MD, RN, CNM) |
Specialty |
Home Address |
Home Phone |
Date of Last Credentialing |
Person and Organization Conducting Credentialing |
Date of Last Privileging |
Person and Organization Conducting Privileging |
Please attach additional sheets, if needed.
SECTION
VII – HISTORY OF FTCA MEDICAL MALPRACTICE CLAIMS (original
deeming) Describe all medical malpractice claims against
the free clinic and/or (annual renewal deeming) Describe all FTCA medical malpractice claims against the free clinic, its deemed health care professionals, and/or its newly sponsored volunteer health care professionals since the last FTCA application submission. |
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Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Please make additional copies of this page to list additional claims.
SECTION VIII – SIGNATURES |
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REQUESTED EFFECTIVE DATE OF FTCA COVERAGE FOR ADDITIONAL VOLUNTEER HEATLH CARE PROFESSIONALS ______________ (No sooner than 30 days from the date of application submission) We certify that this sponsoring free clinic meets the definition of a free clinic found in Section III of HRSA/BPHC PIN 2004-xx and that the information in this application and the related attachments is complete and accurate. EXECUTIVE DIRECTOR: __________________________________________(Print or type) SIGNATURE: _______________________________ Date: ________________ MEDICAL DIRECTOR: ____________________________________________(Print or type) SIGNATURE: _______________________________ Date: ________________ |
Appendix A.2
FREE CLINICS FEDERAL TORT CLAIMS ACT (FTCA) PROGRAM APPLICATION CHECKLISTVolunteer Free Clinic Health Professional Deeming Application – Original or Annual Renewal
APPLICATION SECTION | ITEM COMPLETED AND/OR ATTACHED |
---|---|
Section I – Sponsoring Free Clinic | |
( annual renewal application only) State document indicating legal name change is attached if legal name change occurred since last deeming application was submitted |
|
Section II –Free Clinic Sites |
|
All free clinic sites are listed, using additional copies of Section II, if needed. |
|
Each site is appropriately identified as the main or an additional site. |
|
Section III –Credentialing and Privileging Systems | |
An explanation of all “No” answers is provided in Section V. |
|
The free clinic’s credential and privileging policies are included in the attached quality assurance plan or as a separate document. |
|
Section IV–Risk Management Systems |
|
An explanation of all “No” answers is provided in Section V. |
|
The free clinic’s risk management policies are included in the attached quality assurance plan or as a separate document. |
|
A copy of the free clinic’s quality assurance plan is attached. |
|
Section V–Additional Information Regarding Credentialing, Privileging and Risk Management Systems |
|
An explanation for each “No” answer from Sections III & IV is included. |
|
Section VI – Free Clinic Health Professionals |
|
All free clinic volunteer health professionals that the free clinic wants to sponsor for FTCA deemed status are listed. |
|
Section VII– History of FTCA Medical Malpractice Claims |
|
(original deeming) Descriptions of all medical malpractice claims occurring prior to the submission of this application are included. (annual renewal deeming) Descriptions of all FTCA medical malpractice claims against the free clinic’s deemed volunteer health care providers since the last application submission are included. |
|
Section VIII– Signatures |
|
Original signatures are included for the free clinic’s Executive and Medical Directors. |
|
Other |
|
A copy of the free clinic’s patient notice of limited liability of FTCA deemed volunteer health care professionals is attached. |
Appendix B.1
FREE CLINICS FEDERAL TORT CLAIMS ACT (FTCA) PROGRAM Volunteer Free Clinic Health Professional Deeming Application - Supplemental SECTION I –SPONSORING FREE CLINIC |
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Free Clinic FTCA Number: Free Clinic Corporate Name: (If there has been a legal name change since the last application submission, please attach the appropriate state document indicating the change.) Corporate Address: |
SECTION II –FREE CLINIC SITES List all new free clinic sites where volunteer health care professionals have been/will be providing services (i.e., sites not included in the last deeming application). |
Free Clinic Site - main or additional (circle one): Name: Address:Telephone Number: Fax Number: E-mail: Days/Hours of Operations: Executive Director: Telephone No.: Medical Director: Telephone No. |
Free Clinic Site - main or additional (circle one): Name: Address:Telephone Number: Fax Number: E-mail: Days/Hours of Operations: Executive Director: Telephone No.: Medical Director: Telephone No.: |
Please make additional copies of this page to list any additional sites.
SECTION III– CREDENTIALING, PRIVLEGING & RISK MANAGEMENT CERTIFICATIONS |
___________________________
Free Clinic has: (print or type free clinic’s name)
(check appropriate box) [ ] Has maintained the credentialing, privileging, and risk management systems documented in its last FTCA deeming applicationOR [ ] Has modified the credentialing, privileging, and/or risk management systems since the submission of its last FTCA deeming application. |
Please explain
any changes in the free clinic’s credentialing, privileging,
and risk management systems. |
Please attach additional sheets, if needed.
SECTION IV - FREE CLINIC VOLUNTEER HEALTH CARE PROFESSIONALS List of all new volunteer free clinic health care professionals that the free clinic wants to sponsor for FTCA deemed status (i.e., those not included in the last FTCA deeming application). |
||||||||
---|---|---|---|---|---|---|---|---|
Name |
Professional designation(e.g., MD, RN, CNM) |
Specialty |
Home Address |
Home Phone |
Date of Last Credentialing |
Person and Organization Conducting Credentialing |
Date of Last Privileging |
Person and Organization Conducting Privileging |
Please attach additional sheets, if needed.
SECTION V– HISTORY OF FTCA MEDICAL MALPRACTICE CLAIMS
Describe all medical malpractice claims against the free clinic's newly sponsored volunteer health care professionals.
|
---|
Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Specialty Involved: Allegation: Action taken by the free clinic to prevent such claims in the future: |
Please make additional copies of this page to list additional claims.
SECTION VI - SIGNATURES (No sooner than 30 days from the date of application submission) We certify that this sponsoring free clinic meets the definition of a free clinic found in Section III of HRSA/BPHC PIN 2004-xx and that the information in this application and the related attachments is complete and accurate. EXECUTIVE DIRECTOR: __________________________________________(Print or type) SIGNATURE: _______________________________ Date: ________________ MEDICAL DIRECTOR: ____________________________________________(Print or type) SIGNATURE: _______________________________ Date: ________________ |
Appendix B.2
FREE CLINICS FEDERAL TORT CLAIMS ACT (FTCA) PROGRAM APPLICATION CHECKLIST Volunteer Free Clinic Health Professional Deeming Application - SupplementalAPPLICATION SECTION | ITEM COMPLETED AND/OR ATTACHED |
---|---|
Section I – Sponsoring Free Clinic | |
State document indicating legal name change is attached if legal name change occurred since last deeming application was submitted. |
|
Section II –Free Clinic Sites |
|
Free clinic sites that were not included in the last deeming application are listed, using additional copies of Section II, if needed. |
|
Each site is appropriately identified as the main or an additional site. |
|
Section III –Credentialing, Privileging, and Risk Management Systems Certification |
|
An explanation of any changes in the free clinic’s credentialing, privileging and risk management systems since the original or annual renewal application is included, if applicable. |
|
Section IV – Free Clinic Health Professionals |
|
All free clinic health professionals not listed in the last deeming application that the free clinic wants to sponsor for FTCA deemed status are listed. |
|
Section V– Signatures | |
Original signatures are included for the free clinic’s Executive and Medical Directors. |
Appendix C
FREE CLINICS FEDERAL TORT CLAIMS ACT (FTCA) PROGRAM Sample Patient Notice of Limited Liability of FTCA Deemed Volunteer Free Clinic Health Care ProfessionalsNotice to Patients
To be provided to
the individual patient before health care services are provided,
except in emergency
cases when notice may be provided
as soon after the
emergency as is practicable
or
to a parent or legal guardian when the patient lacks legal responsibility for his/her care under State law.
This is to notify you that under Federal law relating to the operation of free clinics, the Federal Tort Claims Act (FTCA), (See 28 U.S.C. §§ 1346(b), 2401(b), 2671-80) provides the exclusive remedy for damage from personal injury, including death, resulting from the performance of medical, surgical, dental, or related functions by any free clinic volunteer health care practitioner who the Department of Health and Human Services has deemed to be an employee of the Public Health Service. This FTCA medical malpractice coverage applies to deemed free clinic volunteer health care practitioners who have provided a required or authorized service under Title XIX of the Social Security Act (i.e., Medicaid Program) at a free clinic site or through offsite programs or events carried out by the free clinic (See 42 U.S.C. § 233(a), (o)).
Certain free clinic health care professionals providing health care services to patients at this free clinic may be covered by the above Federal law.
Acknowledged: ________________________________(patient signature)
________________________________(patient name, printed legibly)
Date: ____________
[1] If the free clinic imposes charges based on a patient’s ability to pay, this will negate the FTCA coverage of the volunteer(s) for the specific services for which the clinic received payment.
[2] A licensed or certified health care practitioner is an individual required to be licensed, registered, or certified by the State, Commonwealth or territory in which a Free Clinic is located. These individuals include, but are not limited to, physicians, dentists, registered nurses, and others required to be licensed, registered, or certified (e.g., laboratory technicians, social workers, medical assistants, licensed practical nurses, dental hygienists, and nutritionists). The definition will vary dependent upon legal jurisdiction.
[3] Examples of cases in which a free clinic could grant temporary privileges to a LIP in order to meet important patient care needs for a limited period of time include: