Credentialing considerations during a merger or acquisition

If your organization has merged or has been acquired, include crossing all the T’s and dotting all the I’s in he credentialing process. Even though you have a new sister hospital, your hospital’s credentialing process must still be followed until certain structural changes take effect. This means that practitioners from your sister hospital cannot automatically begin practicing at your facility without going through the entire formal initial application process as would any new outside practitioner. There should not be any shortened form or special status afforded to practitioners who practice at a sister hospital, even though they practice at a facility that is under the same health system as your hospital. The assumption, of course, is that your sister hospital has a separate and distinct Medicare provider number. This can be changed so that more than one hospital operates under the same Medicare provider number. The problem is when there are separate Medicare provider numbers among various hospitals under the same system and this detail is ignored in the credentialing process. 

Whether a third-party credentials verification organization (CVO) is utilized or a CVO within the respective health system provides centralized credentialing, the requirements are the same. You must have an executed service agreement, and the CVO must provide documentation to confirm that the required primary source verification (PSV) has been performed and that all requirements under the medical staff bylaws have been met.

Remember, if your hospital has a separate provider number, the PSV done on behalf of another facility is not applicable to your facility. For example, Dr. Smith has practiced at Medical Center A for years and was recently reappointed. Dr. Smith now submits an application to Medical Center B (the acquired or subordinate hospital). Can the CVO utilize the PSVs recently completed in his reappointment to Medical Center A when processing Dr. Smith’s initial application to Medical Center B? The answer is no. 

In addition to separate provider numbers, another important issue is that of credentialing requirements for the types of practitioners (e.g., APNs, PAs, psychologists, etc.) who may be credentialed at Hospital A, but not at Hospital B. This is a medical staff bylaws issue and is related to the associated privileging criteria respective to these practitioners. So how do you settle these issues and keep everyone happy? The good news is that such situations can be reconciled to promote continuity, uniformity, and enhanced quality of care. The bad news is that not everyone likes to change, and in many cases, there are winners and losers.

I have seen hospitals operating under the same system with a shared database but functioning under separate provider numbers, medical staff bylaws, and policies and procedures. According to Michael Callahan, Esq., an attorney at Katten Muchen Rosenman, LLP, in Chicago, such an arrangement can work as long as the application and appointment/reappointment processes are the same and “the same standards apply to everyone. Creating different standards can result in legal liability and confusion.”