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By: Anita Lambert-Gale, RN, MES Executive Director of Nursing United Surgical Partners International.

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Presentation on theme: "By: Anita Lambert-Gale, RN, MES Executive Director of Nursing United Surgical Partners International."— Presentation transcript:

1 By: Anita Lambert-Gale, RN, MES Executive Director of Nursing United Surgical Partners International

2 Each participant will be able to:  Identify major requirements of regulatory and accrediting bodies, for credentialing  Identify why credentialing is important  Identify five (5) significant red flags in medical staff credentialing files  Leave with useful tools to facilitate the credentialing and recredentialing process

3  Florida: Fingerprints all medical license renewals - Discovered 2,000 out of 45,000 physicians have criminal records  2001: nation’s medical boards took disciplinary action against 2,708 physicians  DEA fails to report 2,592 docs to NPDB  Man poses as physician, spoke with and wrote a prescription for an ER patient.  For 16 months, man posed as certified plastic surgeon; operated without medical degree, clinical training, license, or insurance. Today is on the run.

4  Man assumes identity of a psychiatrist and practices for over 5 years.  Maryland doc sued 18 times in 20 years with 9 suits resulting in payments of more than $20 million; Board ignored provision of state law that 3 or more claims in 5 years must be reported.

5  2010 Surgeon at California hospital removed a healthy kidney (wrong site).  The surgeon did not have privileges to perform procedure.  Patient was non-English speaking  Patient latter underwent procedure to remove the diseased kidney, leaving patient with no kidney.

6  July 21, 2011 Gov. Pat Quinn signed into law in Illinois House Bill 1271 ◦ Law mandates “immediate and permanent revocation” of licensure of healthcare professionals convicted of sex crimes, felony or patient battery. ◦ Immediately 11 healthcare professionals lost licensure  June 17, 2011 Gov. Rick Perry signed into law revocation of the medical license of any physician convicted of sexual assault or indecency with a child.

7  September 16, 2011 “Fake Doc Pleads Guilty in $1.2M Fraud Scheme” ◦ 30 year old worked with licensed physicians and used their provider numbers to collect about $1.2 million in false claims with Medicare/Medicaid and private insurance companies. ◦ Was caught while trying to sell patient health information.

8 “Credentialing is complex and exhaustive and requires a high degree of management to assure the proper completion of documentation and follow through with all parties involved in the process.” From Patrick Birmingham, head of EnrollMed Operation of

9 To assure that only qualified practitioners who can demonstrate current clinical competence are granted clinical privileges

10  Required by State and Regulatory Agencies, i.e. State, TJC, AAAHC CMS, OIG  To assist in the risk management of the Facility/Center  To “go the extra mile” to ensure those providing the healthcare services to our patients are competent and qualified.

11  Credentialing for appointment ensures the physician has the training and education to provide services.  Reappointment ensures the physician continues or increases knowledge base to provide care.

12 Documented Court Cases

13  1 st case to hold that hospitals have a corporate duty to monitor patient care being provided in the facility.  Employees must observe condition of patients and report findings to higher authority if attending physician does not do what is clearly proper.  Hospital found liable for negligent treatment of patient by physician.

14  Negligence in reappointment; Negligent credentialing.  Hospital liable for physician’s actions due to its failure to request data from other hospital about basis for its summary suspension. No deficiencies had occurred at Sharp Cabrillo.

15  Negligent Credentialing  Hospital liable for podiatrist’s negligence; failed to obtain malpractice claims data; although medical records department aware of claims.  Court held that a hospital has a duty to both select and review staff physicians adequately.

16  Negligent credentialing; Failure of Initial Credentialing Process  Hospital liable for patient injured by physician who failed to disclose pending malpractice cases and lied about privileges at other hospitals; should have verified information.  Court ruled the hospital had contributed to the patient’s injury simply by allowing the physician to have staff privileges.

17  Medical Staff Bylaws  Medical Staff Rules & Regulations  Credentialing Policies & Procedures

18  Very Important document.  Must be consistent with applicable licensing, certifying and accrediting bodies.

19  Definitions  Purpose and Responsibilities  Medical Staff membership  Categories of the Medical Staff  Allied Health Professional  Medical Staff Clinical Privileges  Corrective Actions

20  Hearing and Appellate Review Procedures  Officers of the Medical Staff  Committees and Functions  Meetings  Confidentiality & Immunity from Liability  Amendments & Adoptions of Bylaws

21  Should be consistent with the Bylaws  Usually will embody the specific standards and level of practice that are required of each member  May be thought of as the Medical Staff’s policies and procedures

22  Should carefully define the steps in the credentialing and privileging process  Should be carefully followed, not to do so places the facility at great risk

23  Issue to applicant cover letter, delineated privilege list and a copy of the Medical Staff Bylaws and Rules & Regulations

24  *Initial granting, verifies by viewing a valid government issues photo ID issued by a state or federal agency  Current licensure  Current DEA  Relevant Education/Training  Hospital Affiliations  Board Certification  Ability to Perform Requested Privileges  Malpractice Insurance (with applicable limits)

25  Malpractice Claims History  Query National Practitioner Data Bank  Criminal Background Check (per your Bylaws)  Peer References


27  Incomplete areas on the Application  Unexplained time gaps in training and/or practice  Positive responses regarding loss of privileges or restrictions or loss of licensure/DEA registration  Frequent changes in location in a short period of time  Pending/settled lawsuits - two fold issue  Non-responses from references  Cancellation notice from Malpractice carrier received during or after process  Negative information from State Licensure Association

28  Require that Clinical Privileges be granted by the Governing Body ◦ Ensure that this is the language in your Medical Staff Bylaws, Rules & Regulations, and any policies. ◦ Especially temporary privileges.

29  Review all clinical privileges in light of what you actually do at your facility.  Delete any privileges on the that you do not perform.  Add any additional privileges that you do in your facility for that specific specialty  TJC requires NPDB with addition of privileges.  DOPs MUST match facility’s approved procedures list

30  Sedation by Non-anesthesiologist should be specifically privileged  Medical Staff Leadership (MEC) must determine criteria to be utilized for granting Sedation privileges (Review community standard)  Verify that the physician meets the criteria  Suggest privileges specify age groups for procedures  Suggest privileges for EKG & radiology interpretation, as appropriate

31  §416.42(c) “The ASC must specify the anesthesia privileges for each practitioner who administers anesthesia, or who supervise the administration of anesthesia by another practitioner. The privileges granted must be in accordance with state law and the ASC’s policy. The type and complexity of procedures for which the practitioner may administer anesthesia or supervise another practitioner supervising anesthesia, must be specified in privileges granted to the individual practitioner.”

32  §416.42(c) “when an ASC permits operating physicians to supervising CRNA’s administering anesthesia, the governing body must adopt written policies that explicitly provide for this.

33  Must make sure that all applicable boxes are checked  Must have documented current competency for the requested privileges

34 FORM TO REQUEST ADDITION OF A PROCEDURE TO THE APPROVED PROCEDURE LIST.  Identify the Procedure:____________________  The usual age range for the patients undergoing this procedure: ___________________  Additional Equipment Needed:_______________  Type of Anesthesia Required: ______________  Projected OR Time: ___ Projected PACU Time: _  Any other information that may assist the MAC and BOG in their decision:_____________  Requesting Physician: _________ Date:________

35  If physician has ECFMG number, you must directly query the ECFMG to verify. AMA Profile is NOT primary source for ECFMG.  You may establish an account with ECFMG for on line verification  Or ECFMG sends out monthly invoice to facility at $25 per inquiry.  Each facility must have separate organization number - if new, state new vendor and number will be assigned to you on report.  ECFMG is primary source for foreign medical school per Joint Commission.

36  What is it?  How do you do it?  What needs to be verified via Primary Source?

37  Utilize the AMA reappointment profile  Be sure to include information regarding performance at the facility.

38  When a physician receives additional education, he/she may apply for amended privileges.  When the facility adds additional programs which will require new privileges.  When the facility revises existing programs and privileges are no longer needed/utilized.  At time of reappointment.

39  Start with a complete application.  Follow the credentialing policies and procedures  Use your checklist  Send out letters within 10 days of receipt of application  Send follow-up letters within 30 days  Request the assistance of the practitioner if you are having difficulty getting responses

40  National Practitioner Data Bank  State Licensing Board  DEA & if applicable State Specific  AMA Profiles (American Medical Association)  OIG Sanctions (Office of Inspector General)  GSA (Exclusions)  Criminal background  Some Healthcare System have on-line verification for Medical Staff Membership and Privileges

41  Telephone verifications ◦ complete appropriate telephone verification form and sign/date  Fax verifications ◦ sign/date faxes received  Use Outlook to create tickler file (reminders for follow-up letters) Feel as though you’ve been asked to pull a rabbit out of a hat?

42  The reappointment process focuses on the practitioner’s professional behavior and competence while functioning at the institution  Time frames vary, usually every two years (refer to state regulations, TJC every 2 years, AAAHC every 3 years)  Reappointment standard is surfacing as one of the most problematic standards for facilities - greater survey focus

43  Keys to Success - thorough planning and follow through  Use the data base to review the number of reappointments scheduled to be processed within a particular quarter and plan your time accordingly

44  Take a proactive approach  Send reappointment materials to physicians 4-5 months prior to expiration of privileges  Send materials registered mail (Common obstacle to timely reapplication completion is a physician’s failure to return his or her reappointment materials)  Follow-up with reminder letters or telephone calls

45  Quality Data - (Internal information gathered into provider profile)  Volume, medical record completion and clinical pertinence, risk management, results of peer review, patient and staff complaints, aggregate performance data, (medical assessment and treatment of patients, blood, drug, operative/invasive procedures, UR, departures from established patterns of clinical practice, compliance with bylaws/rules and regs/policies, and meeting attendance  Missed the deadline?  Inform LIP he/she would be required to cease providing care in the facility until the reappointment process is completed Combating Delays, Cont.

46  Medical Education, Internships, Residencies and Fellowships - these elements are considered static, and therefore do not need to be reverified

47  Most states now have an online service  Follow up on any indication there is something confidential or adverse  Read the material thoroughly!

48  Check web site for OIG or GSA sanctions at appointment and reappointment.  If physician has been sanctioned and on your staff and are seeing patients, you could potentially lose reimbursement on patients seen by physician.   Statement that there is “no report” is what you want to obtain

49 Suggestion - Have any adverse information initialed by Medical Director as evidence that this was considered in the appointment/ reappointment process.

50  - major site for credentialing information - also provide free weekly newsletter via e-mail; sign up at web site  - National Association of Medical Staff Services

51  Must be provided for within your Bylaws  Must follow your Bylaws

52  For important patient needs: Current licensure ◦ Current competence Both of these can be accomplished by a phone call.

53  New Applicants ◦ Current licensure ◦ Relevant education training or experience ◦ Current competency ◦ Ability to perform the privileges requested ◦ NPDB ◦ Criteria identified in the bylaws, rules & regs

54  New applicants must have the following ◦ A complete application ◦ No current or previously successful challenge to licensure or registration ◦ Not been subject to involuntary limitation, reduction, denial, or loss of privileges, when applicable to discipline

55  Joint Commission states the “Administrator or designee grants temporary privileges for meeting important patient needs and for new applicants upon the recommendation of clinical leadership or the medical director.”

56 When an applicant with a complete, clean application is waiting for review by the MEC and Governing Body: ◦ Must have verified current licensure, relevant training or experience, current competence, ability to perform privileges requested ◦ Must have queried NPDB and evaluated report

57 When an applicant has a complete application: ◦ No current or previously successful challenge to licensure or registration ◦ Not been subject to involuntary termination of medical staff membership at another organization ◦ Not been subject to involuntary limitation, reduction, denial or loss of clinical privileges. Temporary Privileges

58  LIP fails to provide necessary information in a timely manner.  Facility fails to verify necessary information in a timely manner.

59  Any time a physician surrenders his privileges (temporary or not) while under investigation, this is reportable to the NPDB. Grant temporary privileges before joining staff, start an investigation and temporary privileges have to be revoked, withdrawn, etc, and become reportable to the data bank.

60  Joint Commission defines as any organization that provides information on an individual’s professional credentials.  Further the organization should have confidence in the completeness, accuracy, and timeliness of the information  Joint Commission identifies 10 principles to guide a CVO organization.

61 1. Makes known to the user the data and information it can provide. 2. Provides documentation to the user describing how its data collection, information development, and verification process(es) are performed.

62 3. Provides sufficient, clear information on database functions, including any limitations of information available from the agency (such as practitioners not included in the database), the time frame for agency responses to requests for information, and a summary overview of quality control processes related to data integrity, security, transmission accuracy, and technical specifications.

63 4. Both agree on the format for transmitting information about an individual. 5. User can easily discern what information transmitted by the CVO is from primary source and what is not. 6. For information transmitted by the agency that can go out of date, the CVO provides the date information was last updated from the primary source.

64 7. CVO certifies that the information transmitted to the user accurately represents the information obtained by it. 8. User can discern whether the information transmitted by the CVO from a primary source is all primary source information in the CVO’s possession pertinent to a given item or, if not, where additional information can be obtained.

65 9. User can engage the CVO’s quality control processes when necessary to resolve concerns about transmission errors, inconsistencies, or other data issues that may be identified. 10. User has a formal arrangement with the CVO for communicating changes in credentialing information.

66 “An accreditable organization may use information provided by a CVO after proper assessment of the capabilities and quality of the CVO…a CVO may demonstrate such capability and quality by becoming accredited or certified by a nationally recognized accreditation organization. Primary or secondary source verification is required for items listed

67  9In manual), unless a CVO or an organization performing primary source verification that is accredited or certified by a nationally recognized body is used. If the organization utilizes a CVO or another organization to verify credentials, those entities must perform primary source verification unless such sources do not exist or are impossible to verify.”

68  Tops the of list of problematic standards from virtually all accrediting bodies


70  Anita Lambert-Gale  USPI  Creekside Crossing III  8 Cadillac Drive  Suite 200  Brentwood, TN 37027   (615) 376-7522

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