#5: What Are the Staffing Requirements?

If you’ve been following this blog on the differences between free-standing emergency rooms and urgent care clinics, you may be interested in the staffing requirements.  The laws vary from state-to-state.  We are only reporting on Colorado.

Staffing Requirements of Urgent Care Clinics 

In Colorado, there are no on-site staff requirements for urgent care clinics as they are not held to facility regulation or licensing standards. The only regulations they are held to are through individual licensure of their on-site health professionals, which is overseen by the Department of Regulatory Affairs (DORA).

The American Academy of Urgent Care Medicine (AAUCM) makes suggestions for staffing levels depending on the typical number of patients seen each day. For an urgent care clinic that sees between 35 and 60 patients per day, they recommend two front desk personnel; two back office clinical staff, one of whom is a basic machine operator (BMO) for X-rays and other clinical operations; one physician and one manager with cross-training for drug screens, blood alcohol tests (BAT), etc. This staffing model stays relatively the same, but personnel either increases or decreases, depending on the average number of patients.[i]

Again, these are only recommendations and urgent care staffing levels are not regulated in Colorado.

Staffing Requirements of Free-Standing Emergency Rooms 

To receive licensing in Colorado, FSERs must meet certain organizational and staffing requirements. Like hospital-based emergency departments, FSERs must be staffed 24 hours per day, seven days per week. There is a defined organizational structure with a governing body that oversees the facility and staff. A Colorado-licensed physician must be appointed as a medical director. The medical director oversees the provider staff, which is responsible for delivery of quality care to patients. Additionally, an administrator must be on staff to direct daily activity and develop policies and procedures. Free-standing emergency rooms must also have a board-certified Emergency Medicine Physician on site at all times.[ii]

The CDPHE HFEMS regulation guidelines (2009) broadly identify staffing requirements. Provider staff must be present at all times and at least one, “shall be qualified in basic cardiac life support and advanced cardiac life support” (p. 5).

Other personnel with, “qualifications as met by education, training, and experience necessary to meet the medical needs of the patients,” must also be present at all times (p. 3).3 This includes, “physicians, nurses, and relevant additional professional staff, such as pharmacists.”[iii]

The American College of Emergency Physicians has further recommendations for services and staff to be present at all free-standing emergency rooms. These include:

  • be available to the public 24 hours a day, seven days a week, 365 days per year;
  • be staffed by appropriately qualified emergency physicians;
  • have adequate medical and nursing personnel qualified in emergency care to meet the written emergency procedures and needs anticipated by the facility;
  • be staffed at all times by a registered nurse (RN) with a minimum requirement of current certification in advanced cardiac life support and pediatric advanced life support; and
  • have policy agreements and procedures in place to provide effective and efficient transfer to a higher level of care if needed (i.e. catheter labs, surgery, ICU).[iv]


As you can see, the staffing levels would account for a substantial proportion of the differences in costs between different types of facilities as discussed in Blog Post #3. We hope this information will help you “know where to go” if the need suddenly arises.

[i]  American Academy of Urgent Care Medicine. (2016). Frequently asked questions. Retrieved from aaucm.org/faq/general/default.aspx Accessed February 11, 2016.

[ii] American College of Emergency Physicians. (2014). News Media: EMTALA. Retrieved from http://www.acep.org/News-Media-top-banner/EMTALA/ Accessed February 15, 2016.

[iii] Colorado Department of Public Health and Environment (2016). Community clinics and community clinics with emergency rooms. Retrieved from https://www.colorado.gov/pacific/cdphe/community-clinics-and-community-clinics-emergency-rooms  Accessed February 11, 2016.

[iv] American College of Emergency Physicians. (2014). News Media: EMTALA. Retrieved from http://www.acep.org/News-Media-top-banner/EMTALA/ Accessed February 15, 2016.