Does credentialing by proxy need to be included in the bylaws for the distant site or just the originating site?

As a practical matter, it may seem strange, but your distant site does not need to have credentialing by proxy in its bylaws unless it is also going to be an originating site, explains Catherine M. Ballard, partner at Bricker & Eckler LLP, in Columbus, Ohio. 

"So if I’ve got the Mayo Clinic, for example, it’s most likely going to be the distant site. It’s rarely going to be doing credentialing by proxy. It’s almost always going to be doing traditional credentialing. That is why the smaller hospital can do credentialing by proxy because it can rely upon the bigger hospital doing traditional credentialing. If, however, let’s say the Mayo Clinic realizes that it does not have a service that the Cleveland Clinic has, the Mayo Clinic may choose to engage in a telemedicine contract with the Cleveland Clinic where the Cleveland Clinic is going to be the distant site. In that situation, the Mayo Clinic would now become the originating hospital and, at that point, because it’s going to be relying on the Cleveland Clinic as the distant site, it needs to have credentialing by proxy in the bylaws. But if you are the distant site, the one who is providing the telemedicine services, you do not need to have credentialing by proxy in your bylaws in order to be able to enter into a contract with the other hospital (originating site)."