Practitioners Credentialed & Privileged through the Medical Staff Flashcards
Practitioner Credentialed and Privileged Through the Medical Staff
Medicare Hospital COPS and Interp Guidelines
Interpretive Guidelines 482.22(b)(4)(ii) and 482.12(a)(10)
The hospital governing body has the responsibility, consistent with state law, including scope of practice laws, to determine which types/categories of physicians and, if it so chooses, non-physician practitioners or other licensed healthcare professionals (collectively referred to in this guidance as (‘practitioners’) may be privileged to provider care to hospital patients.
All practitioners who require privileges in order to furnish care to hospital patients must be evaluated under the hospital’s medical staff privileging system before the hospital’s governing body may grant them privileges.
All practitioners granted medical staff privileges must function under the bylaws, regulations and rules of the hospital’s medical staff
The privileges granted to an individual practitioner must be consistent with state scope of practice laws.
Physicians: The medical staff must at a minimum be composed of doctors of medicine or doctors of osteopathy. In addition, the medical staff may include other types of practitioners included in the definition in section 1861(r) of the social security act of a physician:
- doctor of dental surgery or of dental medicine
- doctor of podiatric medicine
- doctor of optometry and
- chiropractor
In all cases, the practitioner included in the definition of a physician must be legally authorized to practice within the state where the hospital is located and providing services with in their authorized scope of practice. In addition, in certain instances in social security act and regulations attach further limitations as to the type of hospital services for which a practitioner may be considered to be a ‘physician.” See 482.12(c)(1) for more detail on these limitations.
The governing body has the flexibility to determine, consistent with state law, whether practitioners included in the definition of a physician, other than doctors of medicine or osteopathy, are eligible for appointment to the medical staff.
For physicians granted privileges only, the hospital’s governing body and its medical staff must exercise oversight, such as through credentialing and competency review, of those other physician practitioners to whom it grants privileges, just as it would for those practitioners appointed to its medical staff.
Non-Physician Practitioners:
Furthermore, the governing body has the authority, in accordance with state law, to grant medical staff privileges and membership to non-physician practitioners.
The corresponding regulation at 42 CFR 482.22(a) allows hospitals and their medical staffs to take advantage of the expertise and skills of all types of practitioners who practice at the hospital when making decisions concerning medical staff privileges and membership.
Granting medical staff privileges and membership to non-physician practitioners is an option available to the governing body; it is not a requirement.
For non-physician practitioners granted privileges only, the hospital’s governing body and its medical staff must exercise oversight, such as through credentialing and competency review, of those non-physician practitioners to whom it grants privileges, just as it would for those practitioners appointed to its medical staff.
Practitioners are described in Section 1842(b)(18)(C) of the act as any of the following:
- physician assistant (as defined in section 1861(aa)(5) of the act
- nurse practitioners (as defined in section 1861(aa)(5) of the act
- clinical nurse specialist (as defined in section 1861(aa)(5) of the act
- certified registered nurse anesthetist (as defined in section 1861(bb)(2) of the act
- certified nurse midwife (as defined in section 1861(gg)(2) of the act
clinical social work (as defined in section 1861(ph)(1) of the act
- clinical psychologist (as defined in 42 CFR 410.71 for purposes of section 1861(ii) of the act
- anesthesiologist’s assistant (as defined at 410.69) or
- registered dietician or nutrition professional
Other types of licensed healthcare professionals have a more limited scope of practice and usually are not eligible for hospital medical staff privileges for hospital medical staff privileges, unless their permitted scope of practice in their state makes them more comparable to the above listed types of non-physician practitioners.
Some examples of types of such licensed healthcare professionals who might be eligible for medical staff privileges, depending on state law and medical staff bylaws, rules and regulations include, but are not limited to:
- physical therapists (as defined at 410.60 and 484.4)
- occupational therapist (as defined at 410.59 and 484.4)
- speech language therapist (as defined at 410.62 and 484.4)
Furthermore, some states have established a scope of practice for certain licensed pharmacists who are permitted to provide patient care, services that make them more like the above types of non-physician practitioners, including monitoring and assessing of patients and ordering medications and laboratory tests.
In such states, a hospital may grant medical staff privileges to such pharmacists and/or appoint them as members of the medical staff. There is no standard term for such pharmacists, although there are sometimes referred to as “clincal pharmacists”
