Credentialing Flashcards
NCQA Provisional Credentialing
- Current application and signed attestation
- PSV of current, valid license
- PSV of past 5 years of malpractice claims or settlements from the malpractice carrier, or NPDB
- No more than 60 calendar days allowed for provisional status
- Medical Director can approve “clean” files; other files go to Credentials Committee
Medical Environments and accrediting Standards
TJC - Hospitals, ASCs
DNV - Hospitals
CMS - Hosp and MCO
NCQA - MCO and CVO
URAC - MCO and CVO
AAAHC - Ambulatory surgery centers
ACHC/HFAP - Hosp and ASCs
Membership/Appointment vs. Privileges
Differences
* Membership categories
* Described in medical staff bylaws
* Rights, responsibilities and prerogatives
* Criteria
* Same or different
* Privileges without membership
* Membership without privileges
* Organizational requirement
Who can provide an example of a practitioner that may hold
privilege without membership?
NPs
Who can provide an example of a practitioner that may hold
membership without privileges?
Private practice providers
TJC Credentialing Decision Communication
TJC Credentialing Decision Communication
Communication of information regarding approval of privileges:
*
Notify practitioner within timeframe defined in Bylaws
*
Orient practitioner to facility (mandated topics)
*
Notify facility representatives
*
Access by key personnel of approved privileges (scope of practice)
*
No required timeframes
NCQA
NCQA Credentialing Decision Communication
Notify practitioners when information obtained during the credentialing process
varies substantially between the source and the practitioner.
Committee decisions must be communicated within 60 calendar days
All initial credentialing decisions
Recredentialing adverse decisions
Notification of the following rights:
Right to correct erroneous information
Receive status of application upon request
Right to review information submitted
URAC Credentialing Decision Communication
Credentialing decisions must be communicated, in writing, within 10 business days.
ACHC, DNV and AAAHC Credentialing
Decision Communication
Standards are silent on timeframe of communication.
Attestation Time Limits
NCQA(CVO) - signed within 305 days of credentialing decision
NCQA (MCO - signed within 365 days of cred decision
URAC - 180 days prior to credentials committee review
ACHA, AAAHC - no time limit , must have at appointment and
reappointment
CMS, DNV,TJC - Not specifically addressed
Licensure Time Limits
NCQA (CVO) - Verified within 120 days of cred decision
NCQA (MCO) - Verified within 180 days of cred decision
TJC - At time of initial appointment, reappointment, renewal or
revision of privileges and expiration.
ACHC - Licensure/sanctions at time of initial appointment and
reappointment for all applicants
URAC - within 180 days of cred decision
DNV - Upon initial and reappointment/sanctions not specified.
Licensure Sanctions Time limits
NCQA (CVO) - Verified within 120 days of cred decision
NCQA (MCO) - verified w/in 180 days of cred decision
TJC - At time of initial appointment, reappointment, renewal or
revision of privileges.
ACHC - At time of initial appointment and reappointment
AAAHC - Initial and reappointment
URAC - verified w/in 180 days of cred decision
CMS, DNV - Sanctions not specifically addressed
Malpractice/Professional Liability HX Time Limits
NCQA (CVO) - most recent 5 years hx must be verified within
120 days of cred decision.
NCQA (MCO) - most recent 5 years hx must be verified within
180 days of cred decision.
URAC - Proof if liability insurance and professional liability
claims hx must be verified within 180 days of cred
decision.
TJC - Coverage and time limit not addressed. (IF addressed in
Medical staff by laws, Rules/Regulations, then must
validate. Must evaluate liability actions resulting in final
judgment prior to granting privileges.
AAAHC - Professional liability insurance, if required by
organization and ongoing, at a minimum, initial,
reappointment and expiration. Sanctions reviewed at initial
and reappointment.
ACHC - Must have evidence of professional liability ins, and at l
least 5 year hx actions resulting in final judgements or
settlements.
DNV - Must have Professional liability insurance, amounts as
required in Medical Staff Bylaws. Review of involvement in
any professional liability action required at initial and
reappointment.
CMS - Not specifically address.
Medicaid/Medicare Sanctions Time limits
NCQA (CVO) - Verified within 120 days of cred decision
NCQA (MCO) - verified w/in 180 days of cred decision
URAC - verified w/in 180 days of cred decision
CMS, TJC - Not specifically address.
ACHC - Must be reviewed Initial and reappointment
DNV - Must be reviewed Initial and reappointment and when
granting temporary privileges.
AAAHC - Must be reviewed Initial and reappointment
Governance
The governing body addresses and is fully and legally responsible for the operation and performance of the organization. This can be done directly or by appropriate
professional delegation.
The governing body must meet at least annually and keep minutes or other records as may be required for the orderly conduct of the organization.
Credentialing
Credentials must be verified according to the procedures established in bylaws, rules and regulations. Provisions must be made for expeditious processing of applications for
clinical privileges. There must be a procedure for obtaining primary or secondary source information.
Credentialing is a three-phase process to assess and validate qualifications to provide services.
- Establish minimum training, experience, and other requirements for physicians and other healthcare professionals
- Establish a process to review, assess, and validate an individual’s
qualifications, including education, training, experience, certification,
licensure, and any other competence-enhancing activities against the organization’s established minimum requirements - Carries out review, assessment, and validation outlined in the organization’s description of the process
The governing body must:
establish and is responsible for a credentialing and reappointment process and applying criteria uniformly to all individuals who provide patient care
approve mechanisms for credentialing, reappointment, and granting of privileges, suspending or terminating clinical privileges, including provisions for appeal of such decisions
either directly or by delegation, make initial appointment, reappointment, and assignment or curtailment of clinical privileges based on peer evaluation (must be consistent with state law)
have specific criteria for initial appointment and reappointment of physicians and dentists
make provisions for expeditious processing of clinical privileges applications
Privileging
The organization has its own independent process of credentialing and privileging that includes review and approval by the governing body.
Appointment or privileges may not be approved solely on the basis that another organization, such as a hospital, took such action, although this information can be used in consideration of the application.
The governing body provides a process for the initial appointment, reappointment, assignment or curtailment of privileges and practice for allied health care professionals
(based on state law and evidence of education, training, experience and competency).
Use of a CVO is acceptable if there is proper assessment of the capability and quality of CVO services
Another health care organization, such as a hospital or group practice, that has carried out primary source or acceptable secondary source verification, provided
it supplies directly, without transmission or involvement by the applicant or other third party, original documents or photocopies of the verification reports it has relied upon. A statement that it has performed verification is not sufficient.
Documents, diplomas, certificates or transcripts provided directly by the applicant rather than by the primary or secondary source are not acceptable.
Summary of Selected HFAP /ACHC Medical Staff Standards
APPLICATION AND REAPPLICATON REQUIREMENTS
Meeting attendance is evaluated at time of reappointment against the requirements of the medical staff bylaws.
AIR HEARING PROCESS - HFAP/ACHC
The hospital shall have a fair hearing plan for members of the Medical Staff (which may include non-physician practitioners as determined by the Governing Body). Individuals involved in Peer Review activities shall be impartial peers and shall not have an economic interest in and/or a conflict of interest with the subject of the Peer Review
activity. Impartial peer would also exclude individuals with blood relationships, employer/employee relationships, or other potential conflicts that might prevent the individual from giving an impartial assessment, or give the appearance for the potential of bias for or against the subject of the Peer Review.
The fair hearing plan outlines the circumstances under which a practitioner may request (or waive) this mechanism:
Denial.
Modification or changes in appointment/reappointment category.
Initial or re-granting of privileges with final review/action by the Governing Body.
REQUIRED COMMITTEES (Standard 03.02.01) - HFAP/ACHC
There are two required committees: Medical Executive and Utilization Review. A Credentials Committee is not required but may be established to perform the function.
In small hospitals, designated members of the professional staff or the staff serving as a committee-of-the-whole may perform these functions.
TIME FRAME FOR PROCESSING APPLICATIONS (Standard 03.06.08) - HFAP/ ACHC
A recommendation shall be made to the Medical Executive Committee (MEC) within 60 days of receipt of completed application. The recommendations of the Credentials Committee (function) will be based on individual practitioner’s qualifications and competency at the time the privileges are requested. All recommendations to the Medical Executive Committee (MEC) shall contain a delineation of the privileges to be extended to the applicant.
ONGOING PROFESSIONAL PRACTICE EVALUATION - HFAP/ ACHC
Ongoing professional practice evaluation (OPPE) information is factored into the decision to maintain existing privilege(s), to revise existing privilege(s), and/or to revoke an existing privilege prior to or at the time of renewal.
The Medical Staff have a process to monitor the competency of its members. Through an ongoing review of performance measurements, negative trends are tracked and trended in a manner that allows the leadership to identify performance issues and implement strategies that will effect change. Prospective and real-time evaluation is
important to ensure the delivery of safe and competent care.
The Medical Staff develop an ongoing professional practice evaluation plan that is applicable to all practitioners
with privileges granted by the governing body. The plan for the evaluation of each practitioner’s professional practice is clearly defined.
This medical staff approved plan addresses each of the following:
1. Reasons for ongoing professional practice performance evaluations
2. Identification of performance indicators specific to each department of the medical staff
3. Data collection methods
4. Individual(s) responsible for data collection
5. Sources of data, e.g., medical records
6. Frequency of data collection
7. Methods for evaluation and analysis of data
8. Confidentiality and security of data
9. Individuals that may access individual practitioner’s professional practice data
10. Explanation that data will be used as a measure of competency and will be
reviewed at time of reappointment to determine eligibility
11. Evaluation of low volume practitioners
12. Triggers for additional, focused monitoring Processes are established to ensure the confidentiality and security of the ongoing professional practice
FOCUSED PROFESSIONAL PRACTICE EVALUATION (Standard 03.15.02)- HFAP/ACHC
The organized medical staff defines the circumstances requiring additional, focused monitoring and evaluation of a practitioner’s professional performance. Indications for
focused professional practice evaluation (FPPE) include:
All initial privileges granted
All new privileges granted following initial appointment
Unacceptable levels of performance or quality of care concerns The FPPE process is designed to be a fair, balanced, and educational approach to ensure the competency of the staff. FPPE is consistently implemented in accordance with the
criteria and requirements defined by the organized medical staff. The individual is provided written notification of the FPPE with a copy in the individual’s credential file.
The Medical Staff Bylaws clearly define the FPPE process and addresses each of the following:
Criteria (triggers) for conducting focused performance monitoring.
Methods for determining the duration of focused performance monitoring.
Indications for an external reviewer.
The department chair is responsible to assign the focused evaluation. The focused evaluation may be defined as either a period of time (e.g., six months) or a specific
number of cases. The focused evaluation may be extended, as defined in the Bylaws.
Data sources for the focused evaluation are defined and may include:
Chart review.
Direct observation.
Simulation.
Discussion with others involved in the care of each patient.
The Medical Staff Bylaws define the unacceptable levels of performance that trigger the need for focused performance monitoring. Triggers may be a single incident or evidence of a clinical practice trend.