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Telemedicine requirements

Credentialing Resource Center Connection, December 6, 2007

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Anne Roberts, CPMSM, CPCS, is the director of medical affairs at Children's Medical Center in Dallas where she oversees the medical administration, graduate medical education, and medical staff services department.

Dear credentialing colleague:

If your organization is accredited by The Joint Commission (formerly JCAHO) and it provides telemedicine services it is important that you are following The Joint Commission's standards related to this practice. Requirements governing the practice of telemedicine depend on whether your organization is the originating site or the distant site: the place where the patient is physically located is considered the originating site, while the place where the practitioner performing the services is located is considered the distant site.
 
Originating sites must adhere to the following requirements:

• The originating site may elect to credential all practitioners through its own credentialing process or, if the distant site is a Joint Commission-accredited organization, they can elect to accept the credentialing of that site. If the originating site chooses to accept the credentialing of the distant site, then it must ensure that the practitioner has privileges at that site to perform the procedures for which it is contracting that practitioner to perform via telemedicine.
• The physicians providing the services are equally responsible for ensuring that they have and maintain the appropriate privileges prior to providing services through telemedicine.
• The originating site must also provide information relevant to assessing the quality of care, treatment, and services provided back to the distant site. At a minimum this information must include all adverse outcomes resulting in a sentinel event that results from the telemedicine services provided and any complaints received from patients, licensed independent practitioners (LIP), or staff at the originating site.
• Additionally, the originating site maintains the responsibility for overseeing the safety and quality of services offered to its patients and must ensure that the clinical services offered are consistent with the accepted quality standards.

Distant sites must adhere to the following requirements:

• The distant site is required to maintain Joint Commission certification, ensure that it appropriately credentials its physicians for the services provided, and ensures that it is monitoring and evaluating those services.
• The medical staff must recommend which clinical services it will permit LIPs to deliver via telemedicine. This can be done by the medical executive committee reviewing and approving the services. The governing board should also approve the services and resources used in providing those services.
• The distant site should also ensure that the nature and scope of services provided is in writing. This is typically covered in a contract with the originating site. The contract can also outline the credentialing process, HIPAA requirements, quality reporting requirements, compensation, and other legal requirements for providing services.

Both sites should also review the Environment of Care standards, which require a written management plan that describes the process that sites use to ensure that they maintain, inspect, and test equipment. MSPs should review all of their telemedicine contracts and compare them to The Joint Commission's standards to ensure that the contracts clearly outline the credentialing criteria and reporting of quality data.

Remember, clear, effective communication is the key to success!

That's all for this week.

All the best,

Anne Roberts, CPMSM, CPCS

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