Overview of the main regulatory bodies Who they are? What they do? - - PDF document

overview of the main regulatory bodies
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Overview of the main regulatory bodies Who they are? What they do? - - PDF document

Debra R. Gre bra R. Green, MPA, CPMSM, CP , MPA, CPMSM, CPCS CS Di Dire rect ctor, Me , Medica cal Sta Staff S ff Servi rvices a and Ge d Genera ral P Pedi diatri ric R c Residenc ncy Prog rogram St Stanf anford Univ Univer


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SLIDE 1

Debra R. Gre bra R. Green, MPA, CPMSM, CP , MPA, CPMSM, CPCS CS Di Dire rect ctor, Me , Medica cal Sta Staff S ff Servi rvices a and Ge d Genera ral P Pedi diatri ric R c Residenc ncy Prog rogram St Stanf anford Univ Univer ersit sity Medic Medical C l Cent nter er

  • St

Stanf anford H Hosp spit ital & al & Clin Clinic ics

  • Luci

Lucile le P Packa ckard C d Chil ildr dren’s H Hospi spital

  • Director of Medical Staff Services and Pediatric Residency

Program for Stanford University Medical Center which includes Stanford Hospital and Clinics and Lucile Packard Children’s hospital in Palo Alto, CA.

  • Oversight of a combined medical staff of approximately 2000

physicians, 300+ Advanced Practice Professionals and 78 General Pediatric Residents.

  • CPMSM and CPCS in addition to a Masters of Public

Administration(MPA) degree with a concentration in Health Care Management and Policy

  • 20+ years of healthcare administrative experience; primarily

academic.

  • Held previous leadership positions in New Jersey and Michigan.
  • Served as an Expert Witness in negligent credentialing and

privileging legal cases

  • NAMSS Director at Large on the NAMSS Board for 5 consecutive

years. Overview of the main regulatory bodies

  • Who they are?
  • What they do?
  • Why they exist?

Overview of Credentialing/Privileging

Standards

  • Requirements
  • Compliance
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SLIDE 2

Who are they?

  • Government Organization
  • Surveyors are typically State DOH employees
  • Gives deeming authority to TJC, HFAP and DNV

What do they do?

  • Validate TJC
  • Can Survey For Cause

Why do they exist?

  • To ensure patient care and quality

Who are they?

  • Private Organization

What do they do?

  • Unannounced Surveys
  • Tracer Methodology
  • Can Survey “For Cause”

Why do they exist?

  • To ensure patient care and quality

Healthcare Facilities

Accreditation Program (HFAP)

  • Deemed Authority since

1965

  • Surveyors are

experienced healthcare professionals

  • Recognized by Fed Gov,

State DOH, Ins Carriers and Managed Care Organizations (MCO)

  • Surveys are unannounced

Det Norske Veritas

Healthcare, Inc (DNV)

  • Deemed status since

9/08

  • Certifies other companies

in additional to healthcare

  • Existed since 1864

(began in Norway) in US since 1898

  • World wide reputation for

quality and integrity

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SLIDE 3

Who are they?

  • Private Organization

What do they do?

  • Accredits: MCO’s, MBHO’s, PPO’s, NHP’s etc.
  • Certifies: CVO’s

Delegated Credentialing Agreements

  • Hospital does the work for MCO or Health Plan

Who are they?

  • Private Organization, non-profit

What do they do?

  • Accredit Ambulatory Healthcare

Organizations, Surgery Centers, Community Health Centers and Medical/Dental Group Practices

  • US Air Force and Coast Guard

Why do they exist?

  • To promote patient safety, quality and value for

Ambulatory health care

Who are they?

  • Private Organization, non-profit

What do they do?

  • Accredit Health Plans and Preferred

Provider Organizations (PPO)

Why do they exist?

  • To promote healthcare quality through

accreditation education and measurement programs

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SLIDE 4

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I) Primary Source verification from Medical School Alternate sources: AMA, AOA, ECFMG AAPA for PA’s (I) Primary source verification of (Highest Level of Credentials) Alternate sources: AMA, AOA, ECFMG (for foreign grads after 1986), state licensing agency (if the state performs PSV) FCVS for closed residency programs (I) Primary Source Verification of Medical Education Must be significant to support request for privileges Alternate sources: AMA, AOA, ECFMG (after 1986), state licensing agency URAC – (I) PSV required History of education and training included on app Can use the state lic Board as a PSV AAAHC – (I) PSV required No alternative sources noted. DNV (I) Primary Source Verification of Medical Education Requirements must be outlined in Bylaws CMS – Not specially addressed in standards (doesn’t mean its not required)

TJC NCQA HFAP

URAC/AAAHC

DNV

(I) PSV required from primary source or equivalent source Alternate sources: AMA, AOA (I) PSV Highest level of credentials (i.e. board certification) Alternate sources: AMA, AOA, state licensing agency, transcripts (sealed), FCVS for closed programs (I) PSV of Training required Documentation must support requested Privileges Alternate Sources: AMA, AOA,

URAC – (I) PSV required only if not board certified History of Education Required on app Can use the state lic board as a PSV AAAHC – (I) PSV required No alternative sources noted.

DNV - Bylaws include criteria for determining privileges including, specific training requirements CMS – Not specifically addressed in standards (doesn’t mean its not required)

TJC

NCQA HFAP

URAC/AAAHC

DNV and CMS

(I) Required (R) Required if there is insufficient practitioner- specific data available Peer with knowledge

  • f applicant

Recommendations should address clinical competence and ability to perform privileges 6 General Competencies (I&R) Peer Review through Credentials Committee with representation from similar types and degrees of expertise (I) Obtain at least 1 peer with the same professional Credential Assessment of physical and mental health in relation to privileges requested. (R) Individual letters not required, can be

  • btained through

PR, Cred Com, Dept Chair or MEC URAC – No specific requirement AAAHC – (I &R) Peer recommendation required DNV- 2 Peer recommendations at (I). Nothing in the standards assess Peer References at (R) CMS – Not specially addressed

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SLIDE 5

How many organizations

perform Work/Affiliation History Verifications?

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

There is no specific requirement for verification of work history. The standards require, at the time of appointment to membership and initial granting of privileges, verification of relevant training

  • r experience must

be obtained from the primary source (s) whenever feasible. (I) PSV not required. A minimum of five years of relevant work history must be obtained through the practitioner’s application or curriculum vitae. Gaps exceeding six months must be reviewed and clarified either verbally or in writing. (I) PSV Required Verification of where the applicant previously had privileges with confirmation of the applicant’s appointment and privilege history, and any pending investigations of disciplinary actions, voluntary resignations, or relinquishments of membership/clinic al privileges URAC – Not addressed in standards AAAHC – (I) Reviewed for continuity and relevance. Document interruptions in practice DNV – Not addressed in standards. CMS – Not addressed in standards

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Clearly documented process for granting Evidence of Physical Ability to perform requested privileges Grant or Deny must be objective and evidence based Must be criteria based No requirement for privileges Must be consistent with demonstrated competency Criteria based Surgical privileges must be delineated based on individual competency URAC – Privileges must be included in the application AAAHC – Criteria based Reviewed and approved by the governing body DNV Criteria Based Practice within scope CMS All patients must be under the care of a practitioner with privileges Privileges can only be granted by the hospitals governing body Assess ability to perform

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SLIDE 6

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Can be granted under 2 conditions:

  • 1. Urgent patient care

need for limited time (PSV current license, NPDB and competency evaluation req)

  • 2. New apps waiting

for MS review and after a complete application and All verifications are complete

Note: No challenges to license, membership or privileges

Process for “provisional credentialing” for first time providers PVS of license, NPDB, completed application with signed attestation File must be valid and verified and approved by Medical Director

  • r qualified physician

Must not exceed 60 days Bylaws provide for the granting of temporary privileges: 1. During review and consideration of application.

  • 2. For

care of specific patient

  • 3. For

locum tenens.

  • 4. For

times of emergency or disaster. PSV of Lic, DEA, Insurance and 1 Ref from previous facility req URAC – Organization can grant “Provisional” Participation status for a limited time when justified by continuity or quality of care issues on approval of senior clinical staff person. AAAHC – Not specifically addressed. DNV Urgent Pt Care Complete app w/o negative or adverse info Not to exceed 30 days Verification of Lic, competence, Ref and AMA (education), NPDB and OIG CMS Not addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I) FPPE – Focused evaluation (i.e. Proctoring) (R) OPPE – Ongoing Evaluation (i.e. data assessment for everyone) Added in MS Chapter in 2008 Not addressed Not addressed URAC Not addressed AAAHC Not addressed DNV Not addressed CMS Not Addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I & R) Doctor must provide information regarding previously successful or currently pending challenges or relinquishment of registrations (I & R) Verify through copy of certificates, NTIS, AMA State CDS certificates must be verified, where applicable (I&R) Application includes actions against DEA/CDS

URAC – (I&R)Evidence of current DEA/CDS May collect a copy of certificate or certificate # Must be verified within 6 months of review and approval AAAHC – (I) evaluated at initial appmt and monitored continually

DNV (I &R) Provider must provide current DEA # CMS Not Addressed

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SLIDE 7

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I & R) LIPS must participate in Continuing Education Documented Considered in Privilege process Should be relevant to clinical privileges requested Not Addressed May request evidence of CME every 2 years URAC Not Addressed AAAHC Not Addressed for Medical Staff Members DNV Should participate in CME related to privileges CME should be considered at reappointmen t CMS Not addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Not required unless outlined in bylaws Most hospitals require it Primary source verification not required (I & R) Attestation by doctor or copy

  • f policy showing

dates and amount

  • f coverage or

Face Sheet from the carrier Federal Tort letter

  • r attestation from

practitioner of Fed Tort is ok Must have evidence of PLI coverage Must have current certificates showing amount (s) of coverage

URAC – Proof of PLI included on application A cover sheet or attestation from ins company is sufficient to prove coverage AAAHC – Req only if

  • rganization requires

it Review information related to refused or cancelled coverage at (I&R)

DNV Not addressed CMS Not addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I & R) evaluate evidence of “unusual pattern” or “excessive” number of actions resulting in a final judgment. (I & R) Attestation by

doctor or copy of policy showing dates and amount of coverage or Face Sheet Verify history of claims that result in a settlement paid by or

  • n behalf of the

practitioner Confirm via NPDB or carrier last 5 years of settlements

(I&R) Doctor must provide malpractice history for past five years. Organization verify history that resulted in settlements or judgments paid for practitioner. Verified through carrier or NPDB URAC – provider must include claims history on app AAAHC - provider must include claims history on app and evaluated DNV (I&R)

  • rganization

must review involvement in any action CMS Not addressed

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SLIDE 8

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Must query at granting of initial, renewal and when a new privilege is requested. Query if you can’t

  • btained last 5

years of claims from Insurance carriers. Use as alternate source for sanctions or limitations on licensure Must query at granting of initial and renewal URAC - Not required, but can be used to verify license and Medicare and Medicaid sanctions AAAHC - required at (I & R). PDS is acceptable. DNV (I) required only if Temporary Privileges are requested CMS Not addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Terminology is not used in Medical Staff Standards Required under HR Hospital Standards Not specially addressed Application must attest to his/her history of loss of license and felony conviction and lack of illegal drug use. *Attestation Statement Application must request information regarding any criminal history. Investigation must be conducted based on information provided on the application. URAC –Not specially addressed AAAHC - Not specially addressed DNV Required only if State requires it CMS Required only if State requires it

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Verification not required unless bylaws /policy require board certification Organization Specific Verify through ABMS, AMA, AOA or specialty board Not required, but if practitioner says they are Board Certified, it must be verified (R) Required to determine if still current Verify Through ABMS, AMA, AOA, state licensing agency if confirmed by licensing board (I) Not required, but if practitioner says they are Board Certified, it must be verified URAC - Not required but verify if practitioner states they are board certified AAAHC – Verify

  • n initial

application and ongoing basis DNV Not addressed CMS Not addressed

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SLIDE 9

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

May not exceed 2 years At least every 36 months Counts the 36 month cycle to the month, not to the day. (i.e Jan 5, 2007 to Jan 29, 2010 is

  • k)

May not exceed 2 years URAC - At least every 36 months Counts the 36 month cycle to Month AN AND day. (i.e Jan 5, 2007 to Jan 28, 2010 is NOT ok) it must be Jan 5 to Jan 5 every 3 yrs AAAHC – as defined by state law, not to exceed 3 years DNV May not exceed 3 years (defined by state law) CMS Recommends every 24 months

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I & R) Primary source verification required at initial appointment, reappointment, revision of privileges and at time of expiration Current and Valid Verify through state licensing board (I & R) Primary source verification Must be current and valid In effect at time of credentialing decision Verify through state license board (I & R) Primary source verification required URAC – (I&R) PSV required Current and valid AAAHC – (I&R) PSV required DNV (I & R) Primary source verification required CMS Not specifically addressed in standards

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

(I & R) The doctor must provide information regarding challenges or relinquishment of license *Attestation question State Licensing Board FSMB can used as PSV (I & R) Primary source verification required Verify through state licensing board NPDB/PDS and FSMB can be used as PSV Application must include current or pending challenges (I & R) Must be reviewed for each applicant FSMB and FACIS can be used at PSV URAC – History of sanctions should include at least a 5 yr history NBDB can be used AAAHC – review

  • f sanctions

required at (I&R) DNV Addressed for TP

  • nly

CMS Not specifically addressed

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SLIDE 10

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Not addressed

(I&R) Current or previous sanctions must be verified Ongoing Monitoring required between re-credentialing cycles Verify through AMA, NPDB, OIG, FSMB, FEHB, State Medicaid Agency Application must request information regarding Medicare Medicaid Sanctions URAC Must be reported

  • n application

Can use NPDB as PSV AAAHC Must be disclosed and reported on application as well as evaluated at (I&R) DNV (I) Must be reviewed before Temporary Privileges are granted. CMS Not Specifically addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Disaster privileges may be granted to volunteer LIPs when the Emergency Operations Plan has been activated *removed from the MS Chapter, it now resides in EM 02.02.13 Not specifically addressed. The hospital has a plan for dealing with clinical volunteers during emergency /disaster. This plan should provide for primary source ID from the volunteer’s hospital (A documented phone call is acceptable). The hospital should use volunteers as appropriate within the scope of their license/certification.

URAC

Not specifically addressed.

AAAHC

When hospitalization is needed due to emergencies, the

  • rganization may have a

policy for credentialing and privileging physicians and dentists who have admitting privileges at a nearby hospital.

DNV

Not specifically addressed. Identification, availability and notification of personnel that are needed to implement and carry out the hospital’s emergency plans should be considered when developing the Comprehensive emergency plans.

CMS

Not specifically addressed.

Be prepared to

Be prepared to imp implement disaster privi ement disaster privileg eges es in the event of an Emerg the event of an Emergency ncy ……devel ……develop a

  • p a

process, process, not just a not just a policy policy

Tool # 2 – Disaster Credentialing Tool Kit

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SLIDE 11

Inc

Includes:

  • Disaster Credentialing Policy
  • Employee Roster with Phone #s
  • Disaster Privileging Tracking Logs

(multiple copies)

  • Disaster Privilege Forms (multiple

copies)

  • Excerpt from Bylaws regarding

Disaster Privileges

  • List of Links for licensure verification
  • Written process for staff to follow
  • Name Badges
  • Markers
  • Ink Pens

To be completed by Medical staff services L Name F Name MD, DO, NP, PA, DDS, DPM, PHD Specialty Lic # Type ID Provided (See Key – A required) Lic Verified (Date) Verified In 72 hrs Y/N MS Member Y/N PRIV FORM COMP Y/N

SAMPLE

DOCTOR MD MED 123456 A, B 1/1/09 Y N Y

ID Type Key A – Govt issued ID – REQUIRED B – ID from another HC Org C – License to practice D – ID from DMAT/MRC/ESARVHP E – ID from Govt entity granting authority to provide care F – Confirmation from another Medical Staff Member VOLUNTEER LICENSED INDEPENDENT PRACTITIONER DISASTER PRIVELEGES FORM I, (print)_______________________________________, certify that I am licensed as a:

 Physician  Podiatrist  Dentist  Psychologist  Nurse Practitioner 

Physician Assistant in the State of_______________________, license #______________, and I certify that I have no restrictions on my licensure to practice. I also certify that I have the training, knowledge, and experience to practice in the specialty of ____________________________________ with no restrictions on clinical privileges at any hospital. I hereby volunteer my clinical services to Stanford Hospital and Clinics/Lucile Packard Children’s Hospital (“Hospitals”) during this emergency/disaster situation and agree to practice as directed and under the supervision of a current member of the Medical Staff at the Hospitals. I agree to wear my ID badge issued by the Hospitals at all times when functioning under these temporary disaster privileges to enable staff and patients to readily identify my status. I agree to abide by all policies at the Hospitals regarding confidentiality of patient information. I also acknowledge that my temporary disaster privileges at the Hospitals shall immediately terminate once the emergency has ended, as notified by the Hospitals, and that these privileges may be terminated at any time without cause or reason, and without right to a hearing or review. ____________________________________________________________ Signature of provider ____________________________________________________________ Date The information as provided by the provider has been reviewed and will be verified, as soon as possible, as

  • utlined in the Policy, by Medical Staff Services. On this basis, this provider is herby granted temporary

disaster privileges to treat patients presenting at the Hospital during this emergency/disaster. ____________________________________________________________ Signature of Chief of Staff (or designee) ____________________________________________________________ Date

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SLIDE 12

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Applicant must submit a statement that no health problems exist that could affect clinical privileges Confirmed by PD, Chief of Service or COS or at another hospital at (I) appmt

  • r a Peer already on

staff. Medical staff must evaluate prior to recommending privileges. Current signed attestation from the applicant attesting there are no health issues. Documentation of Health Status included in Professional references Can be a statement regarding the applicants physical

  • r mental health

status related to privileges requested. URAC Application must include a question about physical mental or substance abuse problems AAAHC Organization requires and reviews issues regarding physical, mental and chemical dependency DNV Not specifically addressed CMS Not specifically addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

TJC does not use the term “allied health professionals.” It refers to LIPs and Non-LIPs. PAs and APRNs must be credentialed, privileged, and re-privileged through the medical staff process

  • r an equivalent process

that has been approved by the governing body. Equivalent Defined as: Evaluate credentials, Current competence, Peer recommendations and input from committees including MEC to make a decision about privileges. Non-physician practitioners who have an independent relationship with the

  • rganization and

provide care under the

  • rganization’s medical

benefits must be credentialed. All practitioners providing medical care or conducting surgical procedures either directly

  • r under supervision,

whether employed by the hospital, a physician, or a contracted provider must be credentialed. Annual competency/skill assessment required URAC All practitioners who are participating providers, provide covered health care services to consumers, and appear in the

  • rganization’s

provider directory are credentialed. AAAHC If allowed by the

  • rganization, the board

must provide a process for the (I) appointment, (R) appointment, and assignment or curtailment

  • f privileges and practice

for AHPs (based on State law and evidence of education, training, experience and competence DNV NPs, PAs, DDS, PHD’s can be considered “medical staff in accordance with state law No mention of requirement for credentialing and privileging. CMS MS must be composed of MD and DO, but in accordance with state law, NP, PA CRNA, and CNM can be appointed to MS. Physicians and non- physicians can be granted privileges

TJC NCQA HFAP

URAC/AAAHC

DNV and CMS

There must be a mechanism to determine the applicant is the individual identified in the credentialing documents by viewing either a current picture hospital ID card or a valid picture ID issued by a State or Federal agency, such as a driver’s license or passport.

Not specifically addressed Not specifically addressed URAC Not specifically addressed AAAHC Not specifically addressed DNV Not specifically addressed CMS Not specifically addressed

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SLIDE 13

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Not specifically addressed Statement from applicant required at (I) and (R) in order to inquire about: Illegal Drug Use Inability to perform Loss of Lic/privileges Disciplinary Actions Malpractice Coverage Felony Convictions Attest that the application is correct and complete Medicare deemed Organizations: Must be signed within 180 days of final approval 365 days for non- Medicare deemed Orgs Although not specifically addressed in the standards, the Scoring Procedure for the standard reflecting the responsibilities for all credentialed practitioners instructs surveyors to review a select sampling of files to verify practitioners attest to these responsibilities at appointment and reappointment. URAC The application includes a signed and dated statement attesting that the information submitted with the application is complete and accurate to the practitioner’s knowledge. Time limit is 180 days AAAHC The application includes a signed and dated statement attesting that the information submitted with the application is DNV Not specifically addressed CMS Not specifically addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

There must be a process for evaluation

  • f the credibility of a

complaint, allegation,

  • r concern against a

privileged provider. A process to monitor and investigate member complaints related to the quality of all practitioner office sites is required Must conduct site visits for complaints related to physical accessibility, physical appearance and adequacy of waiting and examining-room space based on

  • thresholds. Implements

appropriate actions and evaluate the effectiveness of those actions at least every six months, until deficient offices meet the thresholds. QAPI functions include monitoring of complaints. URAC Policy must define parameters or triggers

  • f potential quality of

care issues that require further investigation. AAAHC Not addressed DNV The hospital must develop and implement a formal grievance procedure, which includes a referral process for quality of care issues to the Utilization Review, Quality Management or Peer Review functions, as appropriate. CMS The hospital must establish a process for prompt resolution of patient grievances and must inform each patient whom to contact to file a grievance.

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

A governance standard holds the hospital’s governing body responsible to comply with applicable law and regulation. Leaders are responsible to be aware of and comply with local, State, and Federal regulations related to credentialing and privileging

  • f practitioners.

The administrative policies and procedures indicate that

  • rganizations providing

managed care services must comply with applicable Federal, State, and local laws and regulations, including requirements for licensure. Thus, the

  • rganization’s leaders

are responsible for any regulations relating to credentialing. Standards require compliance with applicable law and regulations. URAC Standards require compliance with all applicable Federal, State and local laws. AAAHC Standards require compliance with all applicable Federal, State and local laws. DNV Standards require compliance with all applicable Federal, State and local laws. CMS The governing body must assure that the medical staff has bylaws and that those bylaws comply with State and Federal law and the requirements of CoPs.

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SLIDE 14

TJC

NCQA HFAP

URAC/AAAHC

DNV/CMS

Organizations that use information from a CVO should have confidence in the completeness, accuracy, and timeliness of that information. Evaluation of agency can include; processes utilized, limitations

  • f information

available, identification of primary source info versus secondary source information, quality control measure, data integrity, security and transmission. CVOs are allowed to be used and credentialing policies and procedures include the process used to delegate credentialing and re- credentialing, what can be delegated, how the decision to delegate is made. A mutually agreed upon document describing each

  • rganizations

responsibilities is required HFAP refers to a Professional Credentialing Organization (PCO). PCO can be used to perform the PSV, but the process for credentialing by the

  • rganization must

reflect the requirements as stated in the standards URAC The organization can delegate credentialing to a network, group

  • r clinic organization

with which they contract. Oversight is required The organization must retain the authority to make credentialing determinations and must conduct an on- site survey every three years. AAAHC CVO is allowed Assessment of CVO’s quality of work is required DNV Not specifically addressed. CMS Not specifically addressed.

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

AMA – MD or PA Education ABMS – Board Certification ECFMG Foreign Medical Graduates AOA – DO Education and Board Certification FSMB – Licensure actions NCCPA certification NPDB – paid claims or privilege suspension/revocation NCQA does not use the language “designated equivalent sources.” The standards refer back to the specific credentialing event to determine an NCQA approved source. FSMB – Licensure actions AMA – MD or PA Education AOA – DO Education and Board Certification ECFMG Foreign Medical Graduates NPDB – paid claims or privilege suspension/revocation ABMS – Board Certification URAC AMA – MD or PA Education AOA – DO Education and Board Certification NPDB – paid claims or privilege suspension/revocation AAAHC Refers to “secondary source” list of 20 http://www.aaahc.org/e web/dynamicpage.aspx? site=aaahc_site&webco de=resource_credential DNV AMA – MD or PA Education AOA – DO Education and Board Certification CMS Not specifically addressed

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Not specifically addressed. The application must include a statement regarding felony convictions. The application requests information regarding any criminal history and a criminal background investigation is conducted based on information provided in the application or as required by Federal and State regulations. URAC Not specifically addressed. AAAHC The applicant must provide information regarding criminal convictions other than minor traffic violations. DNV Not specifically Addressed CMS Not specifically addressed.

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SLIDE 15

TJC NCQA HFAP

URAC/AAAHC

DNV/CMS

Not required. The organization implements appropriate interventions by conducting site visits of offices about which it has received member complaints and those for which established thresholds are exceeded. Not required. URAC Not required. AAAHC Not required DNV Not required CMS Not Specifically addressed

Audit, Audit an

Audit, Audit and More Audits! d More Audits!!!

Tool # 3 – Credentialing Audit Forms

EMPLOYEE # 123

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SLIDE 16

Front of File Folder SHC LPCH Privilege Tab SHC LPCH Board letters # of cases filled in for Core & Spec privs (Reapps Only) Temporary letters (New Apps only) Documentation for privileges (X-Ray with Initials, Sedation, etc...) <90 days to Board Approval (New Apps

  • nly)

Signatures of applicant Service Chief Recommendation Form - All questions answered email (if forms received electronically) ** Electronic email approval attached? ** Date Service Chief approved file Insurance Verification ** Proctors assigned? Claims History ** Approvals dated prior to HCC Date? Insurance - Current Profiles includes Insurance & Medical Education (New Apps only) Profiles includes # of cases done for each privilege (Reapps only) SHC NPDB PDS - Date verification printed (& Initialed) MSO Checklist included/initialed LPCH NPDB PDS - Date verification printed (& Initialed) MSO Checklist complete OIG - Date Verification printed (& Initialed) Application Tab GSA - Date Verification printed (& Initialed) Photo (New Apps Only) References Tab Provider Verification ID'd (New Apps Only) Includes 2 ref for New Appointments If more than 3 month gap in education or work history - documentation Includes 1 ref for Reapps Yes answer on attestation form has documentation Hospital Verifications included Date application signed by provider required less than 180 days to HCC approval AMA or Edu. Verification (New Apps only) CV or Work History Included in month/year format & Initialed (New Apps only) CME OH&S Clearance HealthSteam confirmed (New Apps Only) Academic Appt / Fast Fac Previous Reappointment Application SHC LPCH Evidence Fee collected Reappointment Governing Board date less than 2 years since last reappointment email (if forms received electronically) Previous Governing Board Letter included New App: __________ Reapp: __________

Physician Audit Checklist

HCC Dates: LPCH = 01/19/12 SHC = 01/23/12 Audited by _____________ Facility: SHC _____ LPCH ____ 180 Days = July 23, 2011 (LPCH) or July 27, 2011 (SHC) Provider: _________________________________________ Service(s): _________________________________________ Faculty: _____ ACF: _____ Community: _____ QM/UM/Legal Tab Sanctions & Issues Tab

APP Audit Checklist 2012 Audit Date SHC 01/23/12 LPCH 2/14/12 Audited by _____________ Facility SHC _____ LPCH ____ 180 Days = July 27, 2011 (SHC) or August 18, 2011 (LPCH) New App __________ Reapp _______ APP-Emp _____ APP-Non-Emp _____ Board Letter included 5 Privilege Tab Profile includes Insurance and Medical Education (for New Apps) Delegation of Svcs Agreement(SHC only) Checklist included/initialed

  • Cert. of Competence (SHC Reapp only)

Checklist complete Job Description (SHC only) Temporary Privilege Form (LPCH all; SHC some) Less than 90 days to Board approval ACLS / PALS (if required) Letter from Chief of Staff 6 QM/UM/Legal Tab Recommendation form Insurance Verification All questions answered Insurance Current All boxes checked Claims History All signatures present 7 Sanctions & Issues Tab Date Service Chief approved file NPDB - SHC - Date Verification Printed Approval dated HCC or prior NPDB - LPCH - Date Verification Printed Proctors assigned? OIG - Date D Verification Printed Electronic email approval in file GSA - Date Verification Printed Application Tab 8 References Tab Yes answer on attestation form has documentation New app = 2 peer (1 could be supervising MD) Enter Date signed by provider Reapp = 1 peer Provider Verification ID'd (Non Emp only) 9 QA folder Provider ______________________________ Service ________________________

Not addressed under:

NCQA URAC AAAHC

Very detailed standards for:

TJC HFAP CMS DNV

slide-17
SLIDE 17
  • Prior to Last year, hospitals were required to credential and privilege all

telemedicine providers at the “Distant location”. (Even Tele-radiologists in Australia).

  • CMS changed the rule and revised the standard in Last year; published

May 2011

  • New standard effective July 2011
  • Hospitals can now rely on the credentialing and privileging of “Distant

Site”

  • The Joint Commission and HFAP are derived from the CMS
  • Di

Distant Si t Site te: The site where the practitioner providing the telemedicine services is located.

  • Originat

inating Sit ing Site: The location where the patient is being treated.

Source: The Searcy Exchange June 2011

  • Here are the options that hospitals and CAHs have under the new rule:
  • Option

Option 1: 1: Cr Credentia tialin ling a g and P Privil ivilegin ing P g Provi

  • vide

ded u d under Con Contract ct A distant-site telemedicine entity, acting as a contractor of services, furnishes its services in a manner that enables the originating-site hospital to comply with all applicable Medicare conditions of participation and standards (via contract). OR OR Option Option 2: 2: Cr Credentia tialin ling a g and P Privil ivilegin ing P g Provi

  • vide

ded d with withou

  • ut a

t a Con Contract ct The distant-site hospital providing the telemedicine services is another Medicare-participating hospital. AND AND The individual distant-site physician or practitioner is privileged at the distant-site hospital providing telemedicine services, and that this distant-site hospital provides a current list of the physician’s or practitioner’s privileges. AND AND The individual distant-site physician or practitioner holds a license issued or recognized by the State in which the hospital whose patients are receiving the telemedicine services is located. AND AND The originating-site hospital has evidence of an internal review of the distant-site physician’s or practitioner’s performance under these telemedicine privileges and provides the distant-site hospital this information for use in its periodic appraisal of the individual distant site physician or practitioner. (Sounds like OPPE to me!!) OR OR Option Option 3: 3: Or Origin iginatin ing S g Site te Cr Credentia tials a and Privile ivileges pr practition titioners a at the the di distant s ant site Organizations can credential telemedicine practitioners the same way that they would credential and privilege any other practitioner who provides patient care services to patients at the organization

  • If

If the hosp the hospita ital contr contracts cts f for t telemed lemedicine cine to b to be u used ed in inclu cluding the r ing the radiology,

  • logy, the

the ho hospita ital ver verifies that that the the r radiologist

  • logist is

is li licens censed ed and and/or m meets the ets the o

  • ther

her ap applicab licable le stand standard rds that s that ar are r e requir ired ed b by St State o ate or lo local cal law laws in in both both th the e state ate wh where th ere the practit e practition

  • ner

er is is located located and and the the st state w ate wher ere the p e the pati tient ent is is located located OR OR is is sub subjected ected to the to the cr cred edential entialin ing g and and p priv ivileg ileging p ng process ess thr through the m ugh the medica cal l staf staff to to b be a approved f for provid iding th ing this is servi rvice for t e for the h e hospital al. .

  • Criter

iteria ia that that inc includ udes a es aspects cts o

  • f ind

individual al char character acter, co competence, tr etence, trai aining ning, , ex experi perien ence a and j d judg dgmen ment is is estab establish lished f for the the se select lectio ion n of ind individual als w s working f ing for the the

  • rganiz

ganizatio tion, d , directl ctly o

  • r und

under co contr ntract, a ct, and/or ap appointe inted th through the ugh the f formal m al medica cal l staff a ff appoi pointmen ent pr proc

  • ces

ess; a and, d, t the pers e person

  • nnel w

l working in ing in the o the organiz ganization ar are p e proper erly ly licen licensed sed o

  • r o
  • ther

herwise m ise meet eet al all ap l applicab licable le F Federal, l, State State an and lo local cal law laws. .

  • The go

The governing b ing body is is r resp sponsib sible f e for ser service ices f furnish ished in the in the ho hosp spital ital w whether ether

  • r no

not the t they ar are f furnishe ished un under co contr ntract

  • ct. T

. The o e organization m must eva evaluate te an and s d select lect contr contracted cted ser services ices (includ luding al all jo l joint int v ventur ntures o

  • r shar

shared se service ices) ( (and nd no non-co n-contr ntracte cted ser services) ices) entit entities/ es/ind ndiv ivid iduals uals based sed o

  • n their

their ab abil ility to ity to sup supply p y products ucts and and/or ser services ices in in acco accord rdance ance w with th the o the organiz ganizatio tion’s ’s r requir irements

  • ents. Cr

. Criter iteria f for s sele lectio ction, n, ev evalu aluatio tion, a and reevalu reevaluation tion s shal all be l be es establ tablished

  • hed. Th

The e cr criter iteria f ia for se select lectio ion w n will incl includ ude the r e the requir irem ement ent that the that the contr contracted cted entit entity or

  • r ind

individ vidual to al to provi provide t e the pr prod

  • ducts/servi

ervices i in a a s safe fe a and d eff effect ctiv ive m e manner nner and and co comply ly w with a th all ap applicab licable le N NIAHO O st stand andards, s, and and stand standard rds s re requ quired f ed for a r all c l contra racted ed services.

slide-18
SLIDE 18

Regulati

Regulation:

  • n:
  • Organized medical staff ; operates under bylaws

that are approved by governing body; responsible for quality of care.

Co

Comp mpli lian ance:

  • Bylaws, R&R’s, Cred files, Quality Reports, Meeting

minutes

Regulati

Regulation

  • n:
  • MS composed of MD’s, DO’s according to state law;

may also include others appointed by Governing Body.

Co

Comp mpli lian ance:

  • MS Rosters, Cred Files, Minutes or approved Bylaws

categories.

slide-19
SLIDE 19

Regulati

Regulation:

  • n:
  • MS must conduct periodic appraisals

Co

Comp mpli lian ance:

  • Cred Files, Profiles, Summary Reports of

Credentialing activity, Board minutes documenting last 2 appraisals

Regulati

Regulation:

  • n:
  • MS must examine credentials of applicants for

memb member ersh ship and make recommendation to Board.

Co

Comp mpli lian ance:

  • Definition of Creds Review Process in the Bylaws;

MS minutes that document review and recommendations.

Regulati

Regulation:

  • n:
  • MS must be well organized and accountable to

Governing Body for quality of Medical Care provided.

Co

Comp mpli lian ance:

  • MS Org Chart, Bylaws Description, Board Minutes,

definition of MS Composition in Bylaws, Bylaws approval by Board

slide-20
SLIDE 20

Req

Requirement irement:

  • MS must adopt & enforce.
  • Must be approved by Board; include category

descriptions, H&P requirement and criteria for privileges to be granted; describe MS Organization and applicant qualifications;

Co

Comp mpli lian ance:

  • Bylaws, R&R, Minutes, Medical Records (H&Ps),

Quality reports (H&P timelines data)

Req

Requirement: irement:

  • Secure in all cases of unusual deaths and for

med/legal educational interests.

Co

Comp mpli lian ance:

  • R&R, Autopsy Policy, QA or PI reports; Medical

Record Review.

As of 2007:

As of 2007:

  • No more than 30 days before or 24 hrs after

admission

Ol

Old Requirem d Requirement: ent:

  • No more than 7 days before and 48 hrs after
slide-21
SLIDE 21

Contin

ntinuous Re uous Readiness: adiness:

Increase staff knowledge on policies,

regulations, bylaws, rules and regulations, privileges

Tool # 1 – Credential Jeopardy Game

100 200 300 400 500 100 200 300 400 500 100 200 300 400 500 100 200 300 400 500 100 200 300 400 500

Contact information: Email: DeGreen@stanfordmed.org Phone: 650-497-8920

Website(s) Stanford Hospital: http://medicalstaff.stanfordhospital.org/

  • Luci

cile le Packar Packard Child Children’s n’s Ho Hosp spital: ital:

https://intranet.lpch.org/mss/index.html;jsessionid=E579B5885A691DCEF80629F89C3D4E67.Int1