National Practitioner Data Bank:  A Valuable Health Workforce Tool  National Credentialing Forum February 1, 2018 Denise Nguyen, MPH Division of Practitioner Data Bank Bureau of Health Workforce (BHW) Health Resources and Services Administration (HRSA)

Overview NPDB Purpose & General Provisions Querying & Reporting Attestation General Updates System Enhancements State Licensing Board Compliance Reviews NPDB Guidebook Data Resources Contact Information

Purpose The National Practitioner Data Bank (NPDB) is a health workforce tool, created by Congress, to assist organizations in making well-informed credentialing, privileging, and licensing decisions. Contains information on medical malpractice payments and certain adverse actions related to health care practitioners, entities, providers, and suppliers. ______________________________________________________________________________________________ From Approved presentation: American Health Lawyer Association in June 2017. Image from: openclipart.org – no restrictions on use https://openclipart.org/share

Purpose Created under three statutes to meet several needs: Flagging system for effective credential reviews Protection against unfit practitioners Deter fraud and abuse in the health care system ______________________________________________________________________________________________ From Approved presentation: American Health Lawyer Association in June 2017. Image from: openclipart.org – no restrictions on use https://openclipart.org/share

Purpose NPDB and NCF: A Shared Goal The NPDB and NCF share the goal of improving quality care and ensuring patient safety. We understand the health care industry’s need to have access to tools and resources to engage and retain a quality health workforce. Reporting contributes to the completeness of the information in the NPDB, which adds value for all queriers who rely on the information. Insufficient reporting denies other health care entities information on practitioners with real competency or conduct concerns. ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Types of Information Collected General Provisions Types of Information Collected Medical malpractice judgments, settlements Adverse licensing and certification actions Clinical privileges actions Health plan contract terminations Professional society membership actions Negative actions/findings from private accreditation organizations and peer review organizations Government administrative actions, e.g., exclusions from programs Civil and criminal health care-related judgments ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

General Provisions Types of Transactions Reporting (no charge) Querying (by hospitals and health care organizations) $2 for a one-year continuous query subscription $2 for a one-time query Self-Query (by an individual or organization) $4 ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

General Provisions Confidentiality Information reported to the NPDB is: Confidential Not available to the general public May not be disclosed except as provided by law Penalty up to $11,000 per confidentiality violation ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Civil Liability Protection General Provisions Civil Liability Protection Immunity provisions in Title IV, Section 1921 and Section 1128E protect individuals, entities, and their authorized agents from being held liable in civil actions for reports made to the NPDB unless they have actual knowledge that the information in the report is false Health care entity professional review bodies, their members, and their agents are immune from civil liability in most cases Failure to Report ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017. Organization name published in the Federal Register Potential loss of immunity protections provided for professional review activities for a three year period

Querying and Reporting Details & Sanctions

Who Reports and Queries ______________________________________________________________________________________________ From Approved presentation: Maryland Board of Physicians in November 2017.

Hospital Querying Hospital Querying Must query on: Health care practitioners when practitioners apply for staff appointments (courtesy or otherwise) or clinical privileges (including temporary privileges); every two years for practitioners on staff or with clinical privileges May query on: Health care practitioners with whom the hospital has entered (or maybe entering) employment or affiliation relationships ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Hospital Reporting Hospital Reporting Overview Must report on: Physicians and dentists Adverse clinical privileges actions >30 days related to professional competence or conduct May report on: Other practitioners ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Hospital Reporting Health Plan Reporting Overview Must report on: Practitioners, providers, and suppliers Health care-related civil judgments in federal or state court; other adjudicated actions or decisions May Query on: Practitioners, providers, and suppliers when credentialing or entering into relationships; investigating potential fraud or abuse related to payment or delivery; pursuing civil actions ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Other Health Care Entities Reporting Overview For other health care entities with formal peer review: Must report on: Physicians and Dentists Adverse clinical privileges actions >30 days related to professional competence or conduct May report on: Other practitioners May Query on: Practitioners when conducting professional review activities; entering into employment or affiliation relationships; screening for staff appointments or clinical privileges ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Attestation

Attestation New Compliance Initiative When: Started in August 2017 Who: Community Health Centers (August 2017), Hospitals (February 2018) , Health Plans (August 2018), Medical Malpractice Reporters (2019) What: Entities will affirm that they have reported all legally required adverse actions and medical malpractice reports to the NPDB. Why: To educate entities about their legal obligation to report; and To ensure that they have reported all legally required reports to the NPDB.

https://www.npdb.hrsa.gov/hcorg/attestationGuide.jsp

General Updates

General Updates System Enhancements Streamlined self-query workflow. Practitioners may upload electronic copies of their notarized Self-Query identification verification forms to the NPDB instead of mailing the original, notarized forms to the NPDB. Improved paperless registration renewal process. Allow users to upload their registration paperwork directly to NPDB and shorten the renewal workflow Improved login workflow for agents and Credentials Verification Organizations (CVOs). Agents and CVOs can accomplish querying and reporting tasks for any number of entities with a single sign in. Improved process to handle unknown data elements submitted by entities. Require any reporter who cannot fill in certain required data fields to leave those fields empty and to attest that they have exhausted all means to obtain the information. NPDB has implemented several system enhancements to improve the querying, reporting, and registration workflows. These enhancements include  the following: Streamlined self-query workflow. Practitioners may upload electronic copies of their notarized Self-Query identification verification forms to the NPDB instead of mailing the original, notarized forms to the NPDB. This feature saves time, paper, and postage because the files are received immediately. Also, condense the notary page from 4 pages to 1 page to decrease rejections for notary/signature/missing pages issues and decrease practitioner paper usage by 9700 pages/month.  Improved paperless registration renewal process. Allow users to upload their registration paperwork directly to NPDB and shorten the renewal workflow, saving users time and mailing costs. Improved login workflow for agents and Credentials Verification Organizations (CVOs). Agents and CVOs can accomplish querying and reporting tasks for any number of entities with a single sign in. Improved process to handle unknown data elements submitted by entities. Require any reporter who cannot fill in certain required data fields to leave those fields empty and to attest that they have exhausted all means to obtain the information. This would ensure that any report with missing data would be accompanied by an attestation and would ensure that the fields with unknown values are not used for matching.

General Updates State Licensing Board Compliance Reviews Integrate registration renewal, attestation, and compliance audits NPDB Guidebook Policy corner content Guidebook - Just updating things from policy corner. Wording clarification; nothing to change the intent. Don’t anticipate a comment period Hopefully release summer 2018 A restriction begins at the time a physician cannot practice the full scope of his or her privileges and is reportable to the NPDB once that restriction has been in place for 31 days. For example, proctoring may or may not be reportable depending on the type of proctoring and the length of time it is in effect. If a physician or dentist cannot perform certain procedures without proctor approval or presence, this is considered a restriction on privileges. The inability to practice the full scope of privileges without a proctor's presence or approval is a restriction. Once the physician or dentist is prohibited from performing the procedure without a proctor, his or her privileges are adversely affected. The number of cases required to be proctored at the time of imposition, or the expectation that a restriction be concluded in fewer than 31 days, is irrelevant for reporting purposes. The reportability of the action hinges on whether the restriction is in fact in effect for a period longer than 30 days.

Data

Reports in the NPDB ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Who is Being Reported ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

One-Time Queries ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Continuous Query Enrollees ______________________________________________________________________________________________ From Approved presentation: National Credentialing Forum in March 2017.

Reporting Reports in the NPDB ______________________________________________________________________________________________ From Approved presentation: American Health Lawyer Association in June 2017.

Help When You Need It: www.npdb.hrsa.gov Resources Help When You Need It: www.npdb.hrsa.gov FAQs, brochures, and fact sheets NPDB Guidebook Recorded webinars Instructions for reporting and querying Regulations Statistical data Research tools The NPDB newsletter Customer Service Center Call 800.767.6732 Email help@npdb.hrsa.gov NPDB Compliance Tip Line 301-945-9601 ______________________________________________________________________________________________ From Approved presentation: American Health Lawyer Association in June 2017. Image from: openclipart.org – no restrictions on use https://openclipart.org/share

Contact Information