Credentialing & Privileging

The "training up" of advance practice professionals

Credentialing Resource Center Connection, December 26, 2007

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Sally J. Pelletier, CPMSM, CPCS, is a consultant with The Greeley Company, a division of HCPro, Inc., specializing in the areas of credentialing and privileging.

Dear credentialing colleague:

When I am working with hospitals to create criteria-based privileging for advance practice professionals (APPs), staff members frequently raise questions about the "training up" of APPs. It is often the case that supervising physicians train APPs to perform certain procedures on the job, in the hospital setting, and, at times, without the organization granting the APP the privilege in advance.

In light of this, hospitals should ask themselves:

  • What is our obligation to patients when determining the balance between what the responsible supervising physician (RSP) has determined is appropriate to teach the APP to perform in terms of care, treatment, or services?
  • What procedures will the organization allow the APP to perform within the hospital as approved by the governing body and delineated by his or her clinical privileges?

Both the organization and the RSP have responsibilities to ensure that the APP is not practicing outside the scope of the privileges that he or she has been granted.

The RSP should recognize that even though he or she may determine outside of the organization what procedures or care an APP may perform within his or her office setting, it is the RSP's responsibility to ensure that the APP does not practice outside of his or her defined scope (determined by the privileges granted) within the hospital setting and that the RSP does not order the APP to perform a procedure that is outside the APPs defined scope.

This is an excellent circumstance in which your organization should turn to the Five P's:  Our Policy is to follow our Policy.  In the absence of a Policy, our Policy is to create a Policy.

The organization should be aware of its obligation to determine what privileges it allows APPs to perform, recognizing that in training situations the APPs should first be granted the privilege with defined parameters that allow for the training to occur. For example, in addition to defining the type of education, training, and experience that would be necessary to be eligible to request the privilege, the organization should define additional requirements such as direct supervision and/or proctoring. Also, remember that for new requests for privileges, you always want to follow the steps outlined in your credentialing policies and procedures.

Your governing body should decide whether your organization will allow the "training up" of APPs. If so, your governing board should develop a policy statement that addresses at a minimum:

  • Procedure for the APP being granted the privilege (in other words, a clear procedure for privileging APPs who "train up")
  • Professional liability coverage (i.e. what is the hospital's liability carrier's position?)
  • Method for obtaining the patient's consent

There should also be education and communication to make both the RSP and the APP aware of your organization's privileging process as well as each entities respective responsibilities in that process.

Remember, credentialing has no other master than the patient.

That's all for this week.

All the best,

Sally J. Pelletier, CPMSM, CPCS
http://www.greeley.com/consulting.cfm



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