1. CMS Proposed Teleradiology Standards Also would amend TJC Contract Standard in Leadership chapter What hospitals need to know. Addition to Slides July 2010

2. 2 Speaker Sue Dill Calloway RN, Esq. CPHRM AD, BA, BSN, MSN, JD President 5447 Fawnbrook Lane Dublin, Ohio 43017 614 791-1468 sdill1@columbus.rr.com

3. 3 Credentialing and Privileging (C&P)  Direct care through a telemedical link:  Standard MS.13.01.01 describes several options for C&P LIPs who are responsible for the care, treatment, and services of the patient through a telemedical link  Interpretive services through a telemedical link:  EP 9 in this standard describes the circumstances under which a hospital can accept the C&P decisions of a TJC ambulatory care hospital for licensed independent practitioners providing interpretive services through a telemedical link

4. 4 Operations LD.04.03.09 Contract Definition  Definition of contractual agreement: An agreement with any organization, group, agency, or individual for services or personnel to be provided by, to, or on behalf of the organization.  Such agreements are defined in a contract or in some other form of written agreement;  Such as a letter of agreement, memorandum of understanding, contract, contracted services, contractual services, or written agreement.

5. 5 Operations Contracts LD.04.03.09 LD Standard: Care and treatment provided through contractual agreement are provided safely and effectively,  EP1. Clinical leaders and MS have an opportunity to provide advice about the sources of clinical services that are to be provided through contracts,

6. Operations Contracts LD.04.03.09  July 15, 2010 TJC manual was to be changed related to tele-intepretive reading and hospitals using TJC for deemed status-use of contract in lieu of credentialing and privileging is not acceptable (CMS requires full C&P at this time and different from TJC Standard)  TJC also issues MS.10.01.01 on telemedicine  Next CMS proposed in May 26, 2010 Federal Register to revised CoP for CAH and PPS hospitals  After CMS proposes changes TJC delayed these changes until March 2011 6

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8. CMS Proposes Changes  Stay tuned because CMS is now proposing less burdensome telemedicine credentialing rules  Would allow hospitals to rely on information provided from another location to base C&P decisions regarding physicians and practitioners who use telemedicine at their facility  CMS realizes that credentialing process is difficult for small hospitals that lack resources to conduct traditional credentialing for physicians that provide telemedicine services  Would need to amend MS by-laws 8

9. CMS Proposes Changes  The new rule would still allow hospitals to use a third party credentialing verification organization to compile and verify the credentials of practitioners applying for privileges  The hospital's governing body would still responsible for making all privileging decisions  Physician would still need to hold a license in the state where the hospital receiving the telemedicine service is located  Comment period ends July 26, 2010  Source: Federal Register May 26, 2010 http://www.access.gpo.gov/su_docs/fedreg/a100526c.html 9

10. CMS Telemedicine Privileges Rules  Hospital A has large group of radiologist who want to provide teleradiology services to Hospital B, a small community hospital  Hospital A must and does participate in Medicare (can’t rely on information from non-hospital entities)  The practitioners has privileges at Hospital A and they give Hospital B a list of the practitioners privileges from Hospital A  Each practitioner must hold a state license in the state of the originating site (Hospital A) and licensed by or recognized by the state whose patients are receiving the service 10

11. CMS Telemedicine Privileges Rules  Hospital A reviews the practitioners performance and sends Hospital B the results to be used in the periodic performance review of the practitioners/radiologists  This information must include any adverse events that result from the telemedicine services  Hospital A is required to evaluate the quality and appropriateness of the diagnosis and treatment furnished by its own staff to a CAH hospital  Board is to ensure there is this agreement and that the agreement says distant hospital (A) is meeting these requirements 11

12. CMS Telemedicine Privileges Rules  Hospital A and B need an agreement between them and this must state that Hospital A (the distant hospital) has to conduct credentialing of telemedicine in accordance with CoPs  No distinction made between teleradiology and teleinterpretive service  Board (Hospital B) will grant privileges according to the MS recommendations which can rely on the information from Hospital A now (now an option or can continue traditional method)  CMS has regulations in both Board and MS sections 12