Credentialing/privileging in ambulatory environments
Ambulatory surgery centers have increased in number dramatically over the past two decades. Many are physician owned, some are jointly developed and owned by hospitals and physicians, and some are opened by hospitals as either on-license facilities or off-license facilities. Currently, hospitals receive a different reimbursement for on-license (higher reimbursement) versus the off-license facility, but the gap is narrowing. Many hospitals and healthcare systems have begun to open off-license facilities to stay competitive, e.g., off-license endoscopy centers.
Challenges are most evident in privileging in these hospital-owned or partnered centers. Usually, the on-license facilities are covered by existing hospital privileges, modified for appropriate procedures being done in the ambulatory environment. Off-license facilities, such as ambulatory surgery centers, have to have their own credentialing body and files. Although the hospital may be governed by Joint Commission and Center for Medicare & Medicaid Services credentialing guidelines, and the use of a credentialing verification organization, the off-site facility may do its own credentialing and privileging and use NCQA guidelines. If the off-site facility is under the licensure of the hospital, practitioners with hospital privileges who work primarily at the off-site clinic will be required to undergo the same ongoing competency assessment as those practitioners on the medical staff of the hospital. This may cause differences in the type of privileging performed at each facility.
The off-site facility also must have a separate set of policies and procedures as well as quality oversight. Conflicts arise when deciding who can provide services in the off-site facility (anyone on the hospital medical staff or a vested few), how the privileges are decided (will practitioners have the same privileges as in the hospital), and how new procedures will be introduced and privileged. Involving your MSPs early in the process and as part of the planning team is a crucial first step. If an off-license facility, there is an early need to understand the applicable laws and regulations far in advance so the appropriate planning can be done. Involving your medical staff leadership is a key component but complex if the center is jointly owned by the hospital and a physician group. Decide early what the makeup of the credentialing/privileging advisory group will be and meet early to plan.