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Automatic suspensions

Credentialing Resource Center Connection, August 17, 2006

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Recently, I was involved in a discussion regarding which circumstances should lead to an automatic suspension of a practitioner's medical staff membership and privileges. The question was raised as to whether a hospital should offer a fair hearing to a member who has been sanctioned or barred from receiving Medicare or Medicaid payments.

The Joint Commission on Accreditation of Healthcare Organizations defines automatic suspension in the 2006 Hospital Accreditation Standards as follows:

"Suspensions that are automatically enacted whenever the defined indication occurs, and not requiring discussion or investigation. Examples are loss of licensure, or exceeding the allowed medical record delinquency rate. Privileges are automatically suspended until the license is renewed, or the records are completed, or the delinquency rate falls to an acceptable level."

Failure to meet defined obligations (e.g., completion of medical records, payment of dues) or qualifications for medical staff membership and/or privileges (e.g., proof of current licensure; proof of insurance; avoidance of sanctions by Medicare, Medicaid, or other federal programs) should not trigger a fair hearing and appeal process. Take a moment this week to review your bylaws and make sure that they include language explaining what triggers an automatic suspension, as well as the conditions under which a practitioner would be reinstated.

Automatic suspensions should happen automatically. The practitioner should be notified of the reason for the automatic suspension, and the appropriate parties should be notified that he or she does not currently hold membership and/or privileges at the institution.

This administrative revocation of medical staff membership and/or clinical privileges (i.e. automatic suspension of a practitioner) does not require the action of the medical executive committee (MEC) or the board of directors. However, after an automatic suspension has transpired, the MEC should review and consider the facts of each suspension to determine whether further corrective action is appropriate.

Further, the MEC should delineate circumstances that would

·                   allow for immediate reinstatement,

·                    define conditions for reinstatement after enough time has lapsed in which a re-determination of current competency needs to be made.

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