Credentialing & Privileging

Proctoring conundrums: How to credential an OR observer

Credentialing Resource Center Connection, August 16, 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 Greeley Company's mottos is "things must be made as simple as possible, but not more so."  That statement is attributed to Albert Einstein. 

Another statement that goes hand-in-hand with the first, although they have different origins, is used in every weekly issue of Credentialing and Privileging Advisor: "Credentialing has no master other than the patient."

Both of these principles came to mind when I was recently asked about establishing credentialing requirements for a proctor charged with observing a physician trained in a new procedure, but who needed additional experience before performing the procedure "independently."
The names have been changed and the institution is fictitious, but the conditions posed were as follows:

XYZ Healthcare determined that a proctor was necessary to verify the competence of Dr. Jones, a surgeon who received training at another hospital to perform a new procedure, and who subsequently wished to perform this procedure at XYZ Healthcare. The organization had already established criteria, in accordance with its new technology and procedure policy, that a proctor must oversee the surgeon for the first four or five procedures. However, no physicians currently on the medical staff at XYZ were qualified to serve as proctors. Dr. Jones then asked Dr. Smith, the vice president of medical affairs at XYZ Healthcare, if he may use a proctor from another facility
 
Dr. Jones requested that the hospital allow Dr. Marks-who does not have membership or privileges at XYZ Healthcare, but who has a contract with the manufacturer of the equipment used during this procedure-to observe the procedure and comment via a written report on his competency.  Dr. Jones emphasized that Dr. Marks will be "looking over his shoulder to verify his competence." In other words, Dr. Marks would not be touching the patient or directing patient care. Dr. Jones stated that a third surgeon, Dr. Thomas, who does hold privileges at XYZ Healthcare, will be on standby in case something goes wrong with the procedure. There will also be an agreement with Dr. Marks to provide written reports regarding his observation. Both the surgeon and the proctor assured the organization that the proctor would not make physical contact with the patient nor direct patient care at any time
 
Although the organization did not have a policy to address this particular circumstance, Dr. Smith felt strongly that in this particular circumstance, the proctor should not have to go through XYZ Healthcare's soup-to-nuts credentialing and privileging process. The organization determined thus that there was no need to fully credential Dr. Marks under the circumstances described since he wouldn't be providing actual care, or directing care to the patient.

Moving forward, Dr. Smith decided that it would be a good idea to create a policy to manage similar situations in the future. Dr. Smith decided that the new policy should accomplish the following:

  • Include a purpose statement on proctoring
  • Define circumstances in which proctoring would be used
  • Outline requirements for proctors
  • Incorporate a proctor identification and authorization process
  • Provide patient notification (i.e., consent)
  • Outline a process for notifying operating room personnel or procedure room personnel as appropriate
  • Set limitations on the proctor (e.g., no hands-on management of patient) and establish guidelines outlining the steps the proctor should take if he or she feels that outside intervention is necessary
  • State whether the organization will provide any indemnification (e.g., professional liability)
  • Address which individuals will be responsible for paying the proctor for his or her services
  • Delineate a mechanism by which the proctor will report his or her findings

Dr. Smith's policy also established that minimal verifications would be performed to determine the proctor's identification and qualifications to be a proctor. Further, the organization would confirm the proctor's competence to serve as a proctor for the specific procedure. 

In the end, this institution decided that, at a minimum, it would verify that the physician who is proctoring has equivalent privileges at another facility, and it would obtain evidence of his or her current clinical competence. This could be obtained verbally.  Additionally, the organization planned to query the National Practitioner Data Bank and obtain license verification via the state licensing board's Web site. These verifications would not be for the granting of privileges, but rather to ensure that the individual had met a minimum level of competence to observe the procedure and comment on the surgeon's competency

Editor's note: A future column will discuss suggested mechanisms for managing proctors who are directly involved in the care of the patient.

Thanks to Greeley consultants Todd Sagin, MD, JD; and Carol Cairns, CPMSM, CPCS, for their insight for this column.

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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