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Credentialing health care industry representatives in your hospital

Credentialing Resource Center Connection, December 9, 2004

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I recently received questions from two medical services professionals (MSPs) asking about the need to credential representatives from pacemaker manufacturers who come into their hospitals. In one case, a representative from a pacemaker company was called to the hospital by a medical staff member to check the function of a patient's pacemaker.

Questions related to the credentialing of healthcare industry representatives are not atypical and all hospitals should have a policy on the issue. Medical staff leaders should consider the following three issues as they create this policy:

1. Patient privacy issues

2. Patient safety issues

3. Attending physician desires

Whether you need to credential manufacturer representatives depends upon your definition of credentialing. If you define credentialing as the collection and evaluation of information necessary to make appointment to the medical staff or to make privilege decisions, then the answer is no.

However, if you define credentialing as a process involving reasonable due diligence prior to granting permission to a person to interact with patients and physicians in the facility, the answer is yes.

It is not necessary to make this person a member of the staff nor is it necessary to grant clinical privileges. He or she must, however, be granted permission by the institution authorizing him or her to become involved with patient care. He or she should not be permitted to have access to patient care information unless permitted by hospital policy and within HIPAA guidelines. To allow a manufacturers' representative to see patient data without authorization would not be prudent at all.

Extensive background checking on these representatives would not be necessary if he or she is only advising the physician and not directing care personally. Your hospital policy should address this issue and policy should be created in conjunction with the medical executive committee and proper legal review. Your policy should address issues such as who is permitted to actually touch a patient or direct patient care. It should also consider the circumstances under which representatives may have access to confidential patient information and the circumstances in which the person is authorized to make notations in the record. (The later is probably not a good idea under any circumstances, since this person is simply advising the attending physician about the proper functioning of a piece of medical equipment.)

Note:  A hospital should not permit physicians to use equipment they are not familiar with on any long-term basis. Familiarity should include an evaluation of the effectiveness of the technology in order to assure that the patient is benefiting from its use. It is not unreasonable, however, to have a period of training or education during which an industry representative's expertise and services are necessary. The only prerogatives that should be permitted are those of review and advising the attending physician. Prohibit representatives from insertion, connection, evaluating indications, making a diagnosis, or otherwise involving themselves in direct patient care.

Editor's note: If you a subscriber to the Credentialing Resource Center, watch for the Clinical Privilege White Paper "Healthcare industry representatives in the operating room" in your January issue.

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