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Managing expirables

Credentialing Resource Center Connection, May 31, 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:

One of the typical responsibilities of the medical staff office (MSO) is to manage or track certain information and documentation related to privileged practitioners' to make sure that it has not expired or lapsed. The organization must ensure that practitioners' information is current not only from a risk management perspective, but also to comply with internal policies and external accreditation or regulatory requirements.

The following types of information 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

Those of us who were working as medical service professionals (MSP) prior to the widespread use of credentialing software applications probably remember tracking this information via a manual "tickler" system. My particular plastic file box-it  reminded me of my mother's recipe box-was bright red and I checked it every day to see what I needed to follow up on, and who I needed to contact to verify whether a particular document was current. Of course, the practice at that time was to obtain a copy of the actual document in addition to performing primary source verification.

Today, the vast majority of MSPs track this information using a credentialing software program. The process is much more automated than the old-fashioned paper method (or at least it should be), and with a click of a button the MSP is alerted to any expired information in the system. A couple more clicks and the MSP can notify a practitioner that a current copy of a particular document (such as professional liability insurance or DEA) is required or obtain primary source verification of his or her licensure or board certification. Hopefully, your organization no longer obtains actual copies of documents that are not required; a previous column addressed this issue.

In working with MSOs, I often find frustration on the part of the MSPs who repeatedly attempt to verify or obtain information from physicians regarding documents that have expired and/or lapsed. 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 continually "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.

Hospitals and medical staffs should be proactive and create guidelines within their bylaws and credentialing policies and procedures stating how they will handle a physician who is no longer in compliance with defined administrative criteria for membership and/or privileges. Typically, the organization should define the circumstances that are grounds for an automatic suspension without rights to a hearing. Hospitals also would have flexibility to determine how to handle specific situations (e.g., automatically suspending a credentialed physician's right to prescribe medications to patients if they lose their prescribing authority from the DEA or suspending their clinical privileges (but not membership) for a lapse in insurance coverage. 

It is then the responsibility of the MSP to be knowledgeable about the requirements in the bylaws and to create procedures (with input from medical staff leadership and administration) to manage the process accordingly.

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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