Getting away from semantics, are you close enough to smell patients? If so, it meets my definition of clinical. That could be synonymous with "patient facing". Are you face-to-face with patients?
I would also take into account that when working with comatose patients, you have the experience of dealing with the family members of these patients. The same goes for NICU patinets who are too young to talk. This can be another formative experience (dealing with greiving or troubled family members.)