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March 24, 2020 

Faced with a global pandemic, hospitals across the country have activated their Emergency Operations Plan.  Healthcare’s responsibility to patient safety has never been more important as we face a significant crisis, one that requires everyone to be vigilant and responsible.

Last week, the President passed the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020.  In that Act, authority has been given to waive or modify Medicare requirements related to telehealth services; originating site and geographic requirements.  The Act is also allowing Medicare beneficiaries the ability to receive care through telehealth links such as their smartphones.  Please know, that there are some rules/requirements surrounding this waiver, but the good news is that patient care can now be delivered without the patient coming into the office if it’s not necessary and physicians can bill for these services.

So, what does all this mean for the hospitals?  It opens the door for physicians currently credentialed and privileged in your facility to provide patient care services via a telehealth link.  The Joint Commission recently confirmed in their updated FAQs, if you have a licensed independent practitioner (LIP) currently privileged and credentialed to work within your facility, they can now provide those same services via a telehealth link and would not require any additional credentialing or privileging.  In addition, it is not necessary to separately delineate telehealth as a privilege for those LIPs.

It’s important to keep in mind, that if you are working under your Emergency Response Plan and you have a LIP that is not currently credentialed or privileged at your facility, you will need to follow the credentialing and privileging process for Disaster Privileges.   Once completed, the provider could also deliver those patient care services via a telehealth link as applicable and permitted by your Medical Staff.

In some organizations, medical services professionals (MSPs) are approaching the need for additional physician coverage in order to fill in service gaps with temporary privileges for patient care need rather than disaster privileges.  Each hospital or healthcare system will have different resource needs and MSPs should provide guidance as to whether utilizing disaster privileges or granting temporary privileges for patient care need is the correct process to meet those demands.

Example One – Family Medicine physician already on your staff who is privileged to provide care in your provider-based clinics.  You may choose to grant this individual inpatient privileges using the temporary privileges for patient care need circumstance.

Example Two – You are part of a health system and need to expand the physicians and other LIPs authorization to practice across all hospitals in your health system.  You may choose to utilize disaster privileges in this circumstance in concert with a joint resolution by your governing board.

If temporary privileges are granted for patient care need, those privileges may also include telemedicine, as applicable.  If these requests for temporary privileges come from a distant site telemedicine entity (DSTE) with an agreement to provide services to your organization and they are looking to expand their workforce, then hopefully you are already utilizing credentialing by proxy (CBP) and this can be a very straightforward and streamlined process.

If you do not have an agreement for telemedicine services in place with the distant site following your full process for granting temporary privileges would be the only option unless you are utilizing disaster privileges.

While you must remember to follow your hospital bylaws and policies and procedures pertaining to disaster privileges and/or temporary privileges during this time of crisis, you also need to remember that this is an unprecedented event and your documents may not always provide clear direction.

Greeley’s core mission is to help hospitals deliver high-quality, cost-effective patient care. For more information on how Greeley can partner with your organization during this challenging time, please email info@greeley.com or call 888.749.3054. 

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