Commissioned Corps Management Information Site

Why is it important to have practice hours?

Maintaining clinical expertise ensures that licensed health professionals have the competency and skills to inform policies, programs, and health care initiatives; develop clinical guidance in response to public health threats; collaborate with health care or provider organizations; and engage in clinical practice during a public health emergency.

How do you define practice hours?

There are two types of practice hours: Public Health and Clinical. Public Health practice hours can only be completed by Corps officers in the following health care professions: Preventive Medicine, Dental Public Health and Veterinary Preventive Medicine if they are authorized to receive Health Professional Special Pay (HPSP) (Incentive Pay (IP) and/or Retention Bonus (RB)). Clinical practice hours can be completed by officers in health care professions if they are authorized to receive HPSP (IP or RB) or officers who are deploying in clinical roles.

What counts as clinical practice hours?

Clinical practice hours includes any time providing a direct service to a patient or animal, supervising those providing direct services to a patient or animal, or supporting those who provide the direct service. For example, a medical technologist who performs tests on a patient’s blood is performing clinical practice hours. Officers should define the direct service to a patient or animal on PHS Form 7047.

What are the due dates for practice hours?

PHS 7047 must be submitted:

For Public Health practice hours - Officers in the following health care professions, Preventive Medicine, Dental Public Health, and Veterinary Preventive Medicine, must complete 80 Public Health practice hours annually if they want to receive HPSP (IP or RB).
For Clinical practice hours - Officers in health care professions must complete 80 clinical practice hours annually if they want to receive HPSP (IP or RB).
For Clinical practice hours - Officers deploying in a primary clinical role must perform a minimum of 80 clinical practice hours annually in their clinical discipline or specialty.

On 1 September 2020, officers receiving IP and/or RB must document their clinical hours on the anniversary of their IP/RB agreement (except for officers whose 2020 anniversary date falls before 1 September). Officers receiving an RB/IB will need to submit Form PHS-7047, “Certification of Practice Hours” by 31 December for year 2020 and by their anniversary date every year thereafter.

Officers performing practice hours for a deployment role (i.e., not receiving special pays such as Incentive Pay (IP)/Retention Bonus (RB)) need to submit Form PHS-7047 on or prior to 31 December. Form PHS-7047 must be submitted electronically through CCMIS.

Am I allowed to backdate agreements?

If a pattern of requests for backdating agreements from a particular OPDIV/STAFFDIV/non-HHS organization, the USPHS Commissioned Corps can subject the officer to disciplinary action in accordance with CCD 111.02, “Disciplinary Actions” if this information is falsified.

What happens to my form if it’s not completed and submitted to the CCHQ Practice Hours Manager within 3 months after initiation?

Every quarter (Jan, April, July, Oct), the Practice Hours Manager will delete PHS 7047 that’s currently ‘in process’. For example: If you submitted a PHS 7047 in February and it’s with someone, other than CCHQ, your form will be scheduled for deletion in July that year (May would have marked the 3 month period).

It is the officer’s responsibility to ensure the practice hours are completed and moved forward. Any technical issues should be routed to the CCHQ Helpdesk at cchelpdesk@hhs.gov.

How do officers acquire practice hours?

For Public Health practice hours - Officers in the following health care professions, Preventive Medicine, Dental Public Health and Veterinary Preventive Medicine will obtain their Public Health practice hours by documenting the hours they already spend on official duty activities in their current position/billet.

For Official Duty Activity clinical practice hours - Officers whose official duties include practicing medicine, nursing, dentistry, veterinary medicine etc. will obtain their practice hours by documenting the hours they already spend on official duty activities in their current position/billet (Office of Personnel Management (OPM) Job Code 81, which OPM defines as “clinical practice, counseling, and ancillary medical services” with the provision of direct clinical and related services to patients and clients including examining, testing, diagnosis, treatment, therapy, casework, counseling, disability evaluation, and related patient care). Also, clinical practice while on approved deployments will qualify. They can perform clinical practice hours during their regular duty hours through additional official duty activities added to their billet through completion of Form PHS 7085 “Position/Billet Addendum” (such as working at a federal clinic) or through non-official duty activities at a federal facility or outside organization.

For Non-Official Duty Activity clinical practice hours - Officers whose position/billet with the Corps is non-clinical will need to obtain their clinical practice hours in other ways. These clinical practice hour can be performed after scheduled duty work hours, or on weekends and/ or on annual leave through completion of Form HHS 520 “Request for Approval of Outside Activity.” An officer can accumulate practice hours through activities for an outside organization even if he or she is paid for this work.

If I am not in a clinical position, can I perform clinical hours during work hours?

Officers may be able to perform clinical hours during work hours, but they must seek guidance from their supervisor and agency ethics office to determine if this is permissible.

How do officers document their practice hours?

To document practice hours an officer’s supervisor(s) must attest that the officer completed 80 practice hours annually. All officers who are in clinical positions (i.e., OPM Job Code 81) that are requesting Health Professional Special Pay (IP and/or RB) or in a primary clinical deployment role must submit Form PHS-7047 to validate the 80 clinical or public health practice hours. For Public Health practice hours - Officers in the following health care professions, Preventive Medicine, Dental Public Health or Veterinary Preventive Medicine, must submit the PHS-7047 to document 80 Public Health practice hours annually.

On 1 September 2020, officers receiving IP must document their clinical hours on the anniversary of their most recent date (except for officers whose 2020 anniversary date falls before 1 September. As per CCI 633.01, these officers have until 1 September 2020 to submit their hours (in 2020 only) and must submit their documentation on their anniversary date in subsequent years.)

On 1 September 2020, officers renewing or signing a new 2/3/4 year RB agreement must present documentation showing they met their 80 practice hours requirement in each of the previous 2/3/4 years.

Officers not receiving IP or RB must submit their clinical hours each year by 31 December using Form PHS-7047 “Practice Hours.” (e.g., social worker, dietitian, therapist).

Whenever officers complete clinical hours, they must obtain an authorizing signature on Form PHS-7047 from the on-site clinical supervisor(s). The officer can electronically submit practice hours in CCMIS each year on the anniversary of their most recent IP date (except for Jan-September 2020 as above) or each year by 31 December (for those not receiving IP) Refer to section 821.70 POM, “Certification of Practice Hours” section 5. B for further information.

What happens to officers who cannot show that they have completed 80 practice hours?

In order for the Corps to meet its ongoing response missions, all officers, in accordance with Sections 6-2.a. and 6-2.c. of CCD 111.03,”Conditions of Service,” are required to maintain professional competence and deployment readiness. As determined by the ASH, an officer who fails to meet any condition of service may have his/her records referred to an Involuntary Termination Board, Administrative Separation Board, Involuntary Retirement Board, Medical Review Board, HPSP Review Board or other involuntary separation process.

How do officers submit the Form PHS-7047?

The form PHS 7047 must be submitted electronically in CCMIS. A How to Submit Practice Hours in CCMIS Video can be found here: https://usphstraining.hhs.gov/login/index.php.

What is the supervisor responsibilities related to clinical hours?

Since agency supervisors play an essential role in all aspects of decision-making, CCHQ encourages officers to engage their supervisors from the start of the practice hour’s certification process. When supervisors review a request for engaging in clinical hours as a non-official duty activity, they should consider whether the clinical hours overlap with the officer’s official duties with his/her agency, whether the overlap creates conflict with matters that are critical to the officer’s performance of official duties, and whether the activity adversely affects the officer’s ability to perform his/her job

Who is required to sign the Form PHS-7047 to verify practice hours were performed?

The Form PHS-7047 requires two supervisory signatures: the signature of the practice site supervisor (Section 14) and the officer’s agency supervisor (Section 19). The practice site supervisor is the individual who directly supervises the practice hours the officer is performing and can attest the hours were completed regardless were performed.

How will I know my reported practice hours have been verified and accepted?

Once we verify your Form 7047, we will place your verified form in the practice hour’s section of the eOPF. Your verification will be indicated in this folder.

How do I know if I am in an OPM Job Code 81?

Primary job can be found on your PIR. (Promotion Information Record)

Can practice hours be performed during scheduled duty work hours?

Yes. When those practice hours are performed during scheduled work hours within a federal agency or outside organization as a non-compensated official duty activity.

Can practice hours be obtained from self-employment?

Yes. Practice hours conducted in the form of self-employment is considered a non-official duty activity. Any self-employment, non-official duty activity will require an officer to complete HHS-520, “Request for Approval of Outside Activity” in addition to Form PHS-7047. The HHS-520 will require the approval of an officer’s agency supervisor and will validate his/her practice hours. The same agency supervisor will sign the signature block in Section 14 and 19 on the Form PHS-7047.

Can officers fall into more than one category (official, non-official) of the Practice Hours POM for the purposes of obtaining practice hours?

Yes. An officer can choose to validate all or some of his/her practice hours’ activities if conducting practice hours as an official and as a non-official duty activity; only a minimum of 80 practice hours need be obtained, documented, and validated.

Do practice hours from a deployment of 14 days or more count towards the 80 practice hours requirement?

Yes, as long as the officer was providing a direct service to a patient or animal, supervising those providing direct services to a patient or animal, or supporting those who provide the direct service during their deployment.

Can officers receive station leave for non-compensated work at a federal facility to earn their practice hours?

Yes. In accordance with CCD 127.01 “Annual, Sick, and Station Leave,” station leave is defined as “an authorized absence from duty and station on non-work days, off-work hours, or for a period of less than one work day.” As such, officers may use station leave to perform practice hours as a non-compensated activity in a federal facility or outside organization as long as the activity is an official duty activity.

Has Commissioned Corps Headquarters proactively contacted the primary clinical Agencies (IHS, BOP, ICE) to request support for TDYs for the many officers that will now require computer training and annual clinical hours?

Domestic TDY’s with agencies (IHS, ICE, etc.) are initiated by agencies, computer access and other necessary elements to perform practice hours are typically incorporated into the TDY’s.

Has Commissioned Corps Headquarters considered additional days of absence in order to comply with government pharmacy mandates for initial orientations, computer training, annual local trainings and credentialing before being allowed to conduct clinical hours?

Absences from the duty station are between the officer and the supervisor in regards to official duty.

Why should 0-6 grade officers in administrative supervisory positions be required to do practice hours?

Corps leadership has determined it is in the best interests of the Corps and its officers that all officers maintain competence in their discipline to meet our response readiness mission. Specifically, Sections 6-2.a. and 6-2.c. of CCD 111.03,”Conditions of Service,” requires officers to maintain professional competence and deployment readiness. Per POM 821.77, “Certification of Practice Hours,” officers who are in clinical deployment roles or are applying for Health Professional Special Pays (HPSP) must maintain 80 practice hours annually. Officers may submit a Waiver to the Surgeon General (SG) if they feel they meet the waiver eligibility criteria in accordance with CCI 633.01, “Special Pays and POM 821.77.”

Is there a practice hours requirement for officers assigned outside the continental United States (OCONUS)?

No. In accordance with POM 821.77 and CCI 633.01, officers who are permanently stationed in a location outside the continental United States (OCONUS), except Alaska and Hawaii, must submit a waiver. The waiver process begins with the officer informing his/her immediate supervisor of the request for a waiver. The waiver must be submitted to e-mail address: phspracticehours@hhs.gov with the subject line: Waiver, however the form PHS 7047 must be submitted electronically through CCMIS.

What is an alternative to performing practice hours while awaiting approval of a HHS-520 or agency equivalent?

Officers may choose to perform practice hours as an official duty activity as part of his/her regularly assigned duties in accordance with their billet description. Officers should have an informal position/billet addendum in place prior to submitting form PHS-7047 for certification of practice hours. CCHQ standardized the position/billet addendum in 821.77 “Certification of Practice Hours,” form PHS-7085 is required for approval of position/billet addendum.

Where do I submit Form PHS-7085, “Position/Billet Addendum?”

The PHS 7085 can be uploaded using eDOC-U under “PHS 7085 Billet/Position Addendum”

How often does the Billet/Position Addendum form (PHS 7085) need to be updated?

Only when there’s a change in the officer’s official duty.

Where do I submit the evidence of the completed Practice Hours webinar?

Officers should upload the certificate in the eOPF under ‘Certificate of Completion’.

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