January is a time when many of us reflect on the happenings of the previous year and will set new goals for 2017. Some of the top resolutions include spend more time with family and friends, exercise more, learn something new, and get organized. As MSPs, it is also a good time to evaluate current processes to ensure continued compliance and identify ways in which to increase efficiency and effectiveness of those processes.
Meeting applicable regulatory and accreditation requirements reflects an organization’s compliance with an industry-recognized set of standards. When working with healthcare organizations, my first priority is to identify areas of concern or risk related to CMS and any applicable accrediting body. Below are several areas that I frequently see organizations overlook with regard to the credentialing and privileging process for you to keep in mind:
- Reappointment cycles: Many healthcare organizations are required to adhere to a reappointment cycle that does not exceed two years, but some may inadvertently be extending that timeframe by an extra day because they do not consider that a two-year timeframe does not begin and end on the same day. A compliant two-year reappointment cycle would be two years less one day (e.g. February 1, 2017 through January 31, 2019).
- Practitioner identity: Specific to TJC-accredited organizations, validating the identity of a practitioner prior to delivering patient care must be performed by a representative of the healthcare organization by physically viewing an appropriate form of identification and confirming it matches the individual that appears before him or her. A copy of the actual identification is not required to be maintained, but many organizations utilize a template form or database fields to document compliance. It is important to recognize that a notarized copy of a driver’s license or passport does not meet the intent of this standard.
- Telemedicine: While both CMS and TJC require that the distant-site practitioner is licensed by the state where the patient is located, CMS requires that organizations must also verify that the distant-site practitioner is licensed by the state where the practitioner is located (CoP 482.11(c)). So to ensure full compliance, be sure this CMS requirement is evident in your policies and procedures as well.
Implementing leading practices that exceed regulatory and accreditation requirements is also a common goal of many MSPs to achieve a more risk-adverse and efficient credentialing and privileging process. Consider incorporating the following components into your policies:
- Background checks and drug screens: While these elements are standard operating procedure for employees, many organizations do not consider performing them for all medical staff members and advanced practitioner professionals. While not required by any regulator or accreditor, these elements have become an industry standard practice and if an organization is not performing them, it may be at higher risk for negligent credentialing claims.
- Internet search: The volume of data available at the tip of our fingers is astounding. MSPs can easily obtain additional information on an initial applicant that may be useful when considering a new practitioner for membership or privileges. Keep in mind that any data element, either positive or negative, should not be used solely to make a decision, but is merely another piece of the puzzle that MSPs attempt to solve through the credentialing process.
- Reappointment references: While obtaining professional references is critical at initial appointment, they are not required at reappointment. The information collected through your internal monitoring processes should provide your organization with sufficient information to determine the competence of your active practitioners. Streamline the reappointment process by requiring references only for those practitioners that perform limited to no volume of patient activity within your organization.
Resolve to be compliant in your credentialing process. Let’s start the conversation!