April 6, 2020
On March 18, 2020, The Joint Commission published in their Standards FAQ’s the allowance of an automatic extension of medical staff reappointment and re-privileging beyond the 2-year period under certain conditions, specifically a national emergency that has been officially declared.
It is incredibly rare for The Joint Commission to allow for an extension of a reappointment. But yes, we are in the midst of an unprecedented time that requires change and adaptability to the situation at hand. We are not only required to address the immediate situation, but we also need to think ahead and be strategic in our approach to managing the aftermath once the emergency has ended.
So, let’s review what The Joint Commission published in more detail. The TJC FAQs published on March 18, 2020 state that “if an established provider’s privileges are scheduled to expire during the time of a declared national emergency, TJC will allow an automatic extension of a medical staff reappointment beyond the 2-year period under the following circumstances”:
- A national emergency has officially been declared
- An organization has activated its emergency management plan
- It is not prohibited by State Law to extend the duration of the providers privileges during an emergency
“The duration of the extension cannot exceed 60 days after the declared state of emergency has ended.”
The authorization to allow the extension is pretty straight forward but the implementation of it will really be dependent of the facility specific situation. Reappointment cycles vary across organizations. Some have reappointments set up on a monthly basis, quarterly, or even one time a year in bulk. So, it really is dependent on the schedule.
If your organization’s reappointments are set up on a monthly basis, you are typically working 4 to 6 months in advance of a reappointment date. Therefore, reappointments that are due in May were sent out between November and December, prior to the crisis. In order to meet the May expiration date, those reappointments typically are being presented to the applicable medical staff leadership and/or meetings during the month of April. Due to the crisis, the availability of leadership, meetings and the governing board during April may not be feasible, therefore the reappointments due in May are now at risk of expiring. The extension permitted by TJC would ensure that those reappointments due in May do not expire by implementing the automatic extension.
The same would apply for reappointments that are on a quarterly cycle. Again, most medical staff offices are typically working 4 to 6 months in advance of a reappointment cycle. If you are targeting a June expiration date, the risk of those reappointments expiring is really impacted by the availability of medical staff leadership, meetings and the governing board.
The reality is that there are so many different scenarios that could play out during this time. The delay in the reappointment being processed timely may not even be due to the applicant or the hospital leadership, but rather outside agencies, hospitals and/or peers not responding to your queries. The delays in responses may keep the reappointment from meeting the targeted date, therefore you may be forced to implement the extension to avoid a reappointment expiring.
One additional thing to consider is if communication to the medical staff or medical staff leadership should go out. It’s important to step lightly as the situation could be taken advantage of by certain staff members. If a medical staff member knows about the extension, they may decide they don’t want to complete the reappointment application even if they truly are not impacted by the facilities emergency plan. Unfortunately, it’s a reality that will occur which will further impact the overall consequences of the extensions after the national emergency is over. It truly should be implemented and communicated if in fact a reappointment will expire as a result of the national emergency. If communication needs to be sent, it should be clear that the extension is permitted by TJC and that the extension cannot extend beyond the 60 days once the national emergency is officially over, as declared by the government.
How each organization approaches the automatic extension will certainly vary and should be dependent on the needs of the organization and how each organization is being impacted by the national emergency. Regardless of the approach, it is very important to document the extensions, specifically the effective date or month. It is also recommended that with a written guideline or policy, a list or roster of those reappointments that fall under the extension be included so that you have a way to track and keep a running list. It will be helpful once the national emergency has ended and you are faced with adhering to the 60 days to complete and make the reappointment current. The list may include details as to where in the process the reappointment was when the extension was implemented. Your organization may have processed a month of reappointments but couldn’t take them through the review and approval process, versus a month of reappointments that weren’t processed at all or not even sent out. Knowing what needs to be done will be helpful when the time comes.
The aftermath and impact of the national emergency is yet to be seen, so it would be important for organizations to proceed with caution, if permitted, when it comes to implementing the extension. Don’t implement an extension if it is not necessary. Don’t “stop shop” during this emergency if it’s not necessary. Why? Because the overall consequences and impact of implementing the extension can be in itself overwhelming if it is not done in an organized approach.
The volume of reappointments affected by the extension may be low for some organizations and once the emergency has ended the “catch up” work may be minimal and not have a significant impact on the medical staff office. However, for some organizations the volume may be high and if that is the case, the impact has the potential to be significant. Remember that the extension is only for the reappointments that were due during the national emergency, it is not extended to reappointments that are due after the emergency. Therefore, in addition to now processing reappointments that are due and to remain compliant with the TJC standard, a medical staff services department will now need to fold into your process the reappointments that were given the extension and only have 60 days to complete, process and gain approval by the governing body.
While the allowance of an extension seems pretty straight forward, there are too many scenarios that could play out that won’t necessarily be straight forward. If your organization is faced with having to implement the extension of reappointments and re-privileging, remember to document with an effective date that includes a list or roster of those providers that fall under the guideline, and think ahead with an organized plan once the national emergency has ended that will bring those providers current within the 60 days as required by Joint Commission.
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 firstname.lastname@example.org or call 888.749.3054.