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Q&A: What should I do if I find that a practitioner's credentials file contains expired documentation?

Credentialing & Verification Update, August 27, 2008

Typically, the responsibilities of the medical staff office (MSO) include tracking certain aspects of privileged practitioner's credentials files to ensure that the file is not expired or lapsed. You may, however, encounter a situation in which an applicant for initial appointment has submitted expired documentation or the file of an active practitioner slips through the cracks and contains expired documentation.

What kinds of documents can expire?

In an August 2007 column in Briefings on Credentialing, Sally Pelletier, CPMSM, CPCS, explained that the following documents within credentials files are subject to expiration:

• Healthcare licenses
• Professional liability insurance
• Drug Enforcement Agency (DEA) or controlled substance certificates
• Board certifications
• Other certifications as required by the organization

Expired documentation in an initial appointment application

The best practice for handling applications for initial appointment containing expired documentation is to simply return to the application to the practitioner and point out the expired documentation. If your organization bylaws allow it, you may choose to proceed with the credentialing process knowing an initial applicants' file contains expired documentation with the expectation that renewal can be verified prior to the completion of the credentialing process.

Expired documentation in the credentials file of an active practitioner

Pelletier says:

Rarely do I find a culture that allows the practitioner to continue providing care at the hospital if his or her license has lapsed, although it is not unheard of. However, too often a practitioner is allowed to continue to practice when his or her DEA, insurance, and/or board certification (if required by the organization) has expired. The culture in these institutions is such that the MSO bears the burden of hounding these physicians for the required information. In addition, the MSPs typically hold off on getting the appropriate medical staff leaders involved until they are in a crisis mode and the documentation is past its expiration date.

Pelletier recommends hospitals and medical staffs should be proactive and create guidelines within their bylaws and credentialing policies and procedures stating how they will handle practitioners that are no longer in compliance with defined criteria for membership and/or privileges.

She notes MSPs must work with medical staff leaders to ensure that the burden for meeting criteria for membership and/or privileges (including ensuring that all documentation is current) should rest on the shoulders of practitioners, not MSPs.

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