Understaffed, Overburdened: How Upcoming Workforce Rule Changes Could Impact Your Clinic
By: Drew Duffy, MHA, FACHE, Founder & Managing Director
Healthcare providers across the country are already grappling with burnout, turnover, and talent shortages. Unfortunately, 2026 isn’t offering much relief—just new expectations.
Recent CMS and HRSA guidance hint at increasing scrutiny on staffing patterns, particularly in outpatient settings that rely heavily on allied health professionals and contractors. States like Minnesota are already piloting reforms tied to staffing minimums and credential transparency, and the ripple effect is likely to reach even the smallest practices.
So what’s changing—and how can your clinic prepare?
The Road Ahead: Key Workforce Compliance Shifts Coming in 2026
Credentialing Verification Timelines Will Tighten
Payers and regulators are pushing for faster, more reliable credentialing. Delays in verification can result in claims holds, audit flags, or even suspension of reimbursement.Documentation Standards for Roles and Responsibilities
Expect clearer expectations on role definitions, scope-of-practice documentation, and task delegation—especially for medical assistants, LPNs, and contract staff.Increased Oversight of Third-Party Staffing Arrangements
Clinics using locums or staffing firms may be required to demonstrate that those entities meet the same onboarding, HIPAA, and background standards as in-house hires.Workforce Reporting Requirements
HRSA-funded clinics and Medicaid providers may be required to submit annual staffing reports—including data on vacancies, turnover, and workforce composition.
5 Steps Clinics Can Take Now
1. Conduct a Role Audit
Review every position in your clinic—from front desk to clinical support—to ensure each has a defined scope, supervision plan, and documentation trail.
2. Tighten Your Credentialing Process
Don't wait until a payer demands it. Make sure credentials are verified at hire, tracked, and re-verified on a regular cycle.
3. Review Employment and Contractor Agreements
Ensure language addresses compliance obligations, supervision, data access, and termination protocols. (Yes, this includes locums and per diems.)
4. Start Tracking Turnover and Vacancy Rates
Even small clinics benefit from basic HR metrics. Knowing where you’re losing staff—and why—can help you fix problems before regulators take notice.
5. Standardize Your Onboarding Protocols
From OSHA training to HIPAA attestations, every new team member should go through a consistent, documented onboarding process.
Future-Proofing Doesn’t Have to Be Overwhelming
The coming changes aren’t about punishing clinics—they’re about protecting patients and improving care quality. But navigating new rules, especially while short-staffed, can feel daunting.
At ClearPath Compliance, we help clinics like yours stay ahead of the curve—without burning out your team. Whether you need help refining credentialing workflows, reviewing HR policies, or just a second set of eyes on your staffing documentation, we’re here to help.
📌 Final Thought:
Healthcare’s greatest asset is its people. The more we invest in protecting and supporting our workforce, the more resilient our clinics—and our compliance programs—become.
-Drew
About the Author
Drew Duffy, MD (not practicing), MHA, CPCO, CRCMP, CHCO, CIPP/M, FACHE, is Founder & Managing Director of ClearPath Compliance. With over 20 years in healthcare operations and compliance, Drew draws on his clinical background and extensive expertise, supported by a network of experienced healthcare leaders—to deliver practical, ethical solutions for providers navigating today’s complex regulatory landscape