Q&A: Privileging physicians at clinic practices

Q: If clinic practices are owned by a health system, do physicians need to be privileged even if they don’t come to the hospital?

A: If clinics are owned by the health system but are not under the hospital’s organizational chart, then no, they do not need to be privileged. Let’s say we have the community health system, and we have [a] memorial hospital along with five other hospitals, and then some health clinics. If the hospital does not have a particular health clinic reporting directly to it, the hospital has no obligation during its Joint Commission or CMS survey, or DNV, to privilege these individuals.

But there’s another question that needs to be answered: What state regulations apply? For example, does a health clinic need state licensure to function? If it does, then state law is applicable. For example, if the clinic is billing for Medicare or Medicaid services, my guess is it’s going to need some type of accreditation, some type of deeming authority to bill for those services.

Is a state survey required? Does it need some other type of accreditation? That’s the first question you would need to answer as a system.

Once you know what is required, the second question you need to answer is: Do you believe you have a higher obligation, from a system standpoint, to make sure the practitioners in your system-owned clinic are competent?

I was in an organization not so long ago where the system owned a clinic. It was in the town where the system also had a hospital. Those physicians in the clinic did not go to the hospital; They had a straight ambulatory care practice. If their patients needed hospitalization, they were sent to consultants on that hospital’s medical staff, but the system and the hospital agreed that since these individuals were committed to their community and functioning in their community, they wanted a credentialing process for that site. The system decided to take the best practices of the hospital, and the hospital would assume that verification, and that’s how that system solved the issue.

There’s a two-part answer to that: One is compliance with state regulations and or reimbursement requirements such as Medicare/Medicaid or third-party payers. The other is what does the system desire? What do they want? Because they are now obligated clinically as well as legally for the care that’s provided in that clinic.

- Carol S. Cairns, CPMSM, CPCS, from the webcast, Verify and Comply: Meet Your Top Credentialing Challenges. To order this presentation on demand, click here.