Reappointment Verification: No Longer Good Enough [Sponsored Content]
December 7, 2017
by Francesca Hartop, Founder/CEO Zebu Compliance Solutions. She can be reached at hartop@zebucompliance.com
Medical staff are traditionally reappointed every two to three years, a process that includes at least the verification of licensing, DEA status, disciplinary actions, malpractice history, and some level of peer review. Although still permitted by accreditation bodies, this lax management of a staff member’s practice history derails organizations during malpractice or criminal actions alleging failure to protect patients from dangers that were known, or should have been known.
Challenges
The defense of a two to three year recredentialing gap is very hard to justify in today’s 24/7 news and digital records world. Federally, the Centers for Medicare and Medicaid Services, in conjunction with the OIG (Office of Inspector General), already mandates that sanctions and exclusions be monitored no less frequently than every 30 days. They further require that an organization be able to produce its policy, process, and documentation proving compliance with the monthly sanction/exclusion verification process during an audit.
Historically, confirming medical licenses, malpractice claims, settlements, and disciplinary actions was a time-consuming and labor-intensive process, involving written requests, mailed or faxed responses, phone calls, and copying of original records. But today, if employees, staff, vendors and board members are subject to recurring 30-day monitoring for federal exclusions based on abusive or fraudulent billing, kickbacks, and other administrative failures, how can an organization in good faith verify licensure and discipline only every 2-3 years? This practice only continues because of tradition, and organizations should act swiftly to close this dangerous gap in due diligence.
Risks
No organization wants to answer a plaintiff’s attorney asking:
“Why, if the public record shows that Dr. J was disciplined and settled a claim for sexual battery on a patient at Other Place, did you let them continue practice at Your Hospital, which resulted in my client’s injuries?”
Such cases, claiming negligent credentialing, are becoming more common. They allege either that the hospital’s credentialing process was not followed or, with more prevalence, that the credentialing process was inadequate. In other words, you could have known, so you should have known, and then this outcome would have been prevented.
Today, licensure, disciplinary, and other records are available at the click of a button. (The challenge is that it may actually be the click of a thousand buttons for each staff member, since there are dozens upon dozens of relevant record sources.)
Responses
Continuous credentialing software specifically assists organizations maintain ongoing monitoring of professionals providing or directing care under their facility’s umbrella of responsibility in areas including, but not limited to:
- Federal-level sanctions & exclusions
- State-level sanctions & exclusions
- License status (valid, suspended, revoked)
- License renewal date (for proactive prompts)
- National Practitioner Data Bank (NPDB) reports - including settlements, and denial, loss, or restriction of privileges
- State Board disciplinary reports
- Medicare participation status
- Open Payment Data (for evaluation of potential conflicts of interest)
- Social Security Death Master (identity fraud)
The best systems provide not only the ongoing monitoring of all appropriate databanks and agencies, but also include:
- Automatic audit trail at every step in the process
- Actionable results to achieve resolution
- Reminders of unresolved alerts
- Escalation process
- Explanations and timestamps on all records
- Management reports
- Tools to easily answer/research auditor inquiries
- Enhanced full-service support
- Subject matter expert availability
With 30-day requirements for sanctions and exclusions, in addition to dozens of other licensure-related databases to monitor physicians, nurses, aides, staff, vendors, and board members, facilities understandably struggle to maintain dedicated staff proficient in managing this data analysis and documentation burden in the midst of mission-critical patient care demands. Organizations find themselves therefore contracting with an expert third-party full-service solution to facilitate data collection, communication, review, and documentation. The use of such enhanced services with expert assistance allows facilities to be timely in identifying and addressing risks relevant to their operations.
Welcome to the age of continuous credentialing: knowledge to intervene effectively and quickly, reducing institutional risk and avoidable patient harm.