Risk Management: Credentialing - When is enough enough?
Part I in a series
by Russ Pride, Princeton Insurance Healthcare Risk Consultant
This article is the first in a series to address the day-to-day activities relating to effective, comprehensive credentialing. Like any healthcare-related activity, the credentialing process has become labor-intensive. Primary source verification, thorough documentation and proper oversight are but a few of the elements requiring diligence to effectively mitigate the potential for litigation while ensuring the delivery of quality, patient-centered services. In this issue, we look at
Professional Liability & Licensing
and review the process from dual perspectives: the credentialing facility and the Licensed Independent Contractor (LIC) requesting privileges.
Computer capability and information technology continue to expand at mind-boggling speed! We scan, download, copy, alter, reproduce and generate anything the human mind imagines. The quality of the end product is awesome, even if not authentic.
All the more reason to provide and maintain “original” documents.
What does this mean for the credentialing facility?
Negligent credentialing has become an issue for facilities that become co-defendants in medical malpractice claims. Inconsistent or incomplete credentialing processes suggest lack of oversight and a deficit in the thorough, objective evaluation of each and every LIC’s credentials, including claims history, quality issues, etc. “Rubber-stamping” of credentialing applications is a surefire means of inviting plaintiff attorney investigation of all credentialing procedures. Remember the headlines generated by the actions of Michael Swango (Blind Eye by James B. Stewart, 1999) and Charles Cullen? Recall the intense scrutiny placed upon credentialing as a result of these publicized cases?
Evidence of professional liability insurance helps shield a healthcare facility against potential claims resulting from an LIC’s gaps in coverage.
Certificates of Insurance (or Insurance Dec Pages) generated directly from the LIC’s professional liability carrier or broker provide evidence that appropriate coverage is in effect and continually maintained. As a value-added, no-cost benefit, Princeton Insurance healthcare risk consultants conduct periodic credentialing assessments for our insureds. We encourage our insureds to accept only original insurance certification for LICs. Like any document, evidence of coverage may be altered if an original-issue is not required. In order to expedite an application in the credentialing process, it is understandable that a fax of certification is helpful. Before the credentialing file is deemed “complete,” however, an original should be included with that application.
Current license verification from both the state and FDA (as appropriate) is equally important. There are two avenues available to credentialing bodies with regard to verification: written confirmation from the licensing agency that an LIC’s license is current and valid, or the presentation of the actual license. In the latter instance, we recommend that the LIC present his/her original license(s) to credentialing personnel, at which time a photocopy is made; on this copy is documentation that the original license was viewed, indicating date and by whom. Facilities employing credentialing agencies to conduct the bulk of the credentialing process should verify with those agencies that one or the other avenues outlined above are adhered to routinely.
Extra steps? Yes. Remember: the onus is on the LIC to conform to credentialing criteria mandated by the facility and its Medical Staff Bylaws, Rules and Regulations. Their criteria are further supported by JCAHO’s Comprehensive Accreditation Manual for Hospitals in its Medical Staff (MS) chapter. The far-reaching benefits? Increased protection for the facility against negligent credentialing allegations that appropriate, thorough credentialing is conducted uniformly. Better to invest some extra time now, than to be dragged into a tedious lawsuit and/or public relations quagmire at some point in the future.
What does this mean for the Licensed Independent Contractor?
Physicians no longer suffer the rigors of credentialing alone. The advent of licensing and stricter, finely articulated professional standards now impact a full spectrum of allied healthcare professionals (psychologists, therapists, social workers, CRNAs, CNMs, etc.).
There is no doubt that fulfilling the requirements of an application for privileges is a tedious process. The upside to this scrutiny affords you – the LIC – greater protection. A different set of eyes reviewing your application may reveal a concern of which you will want to be aware and have the opportunity to correct. Regard any request for clarification or additional information as the opportunity to review your professional situation and make positive changes that will afford you greater protection from a potential claim in the future.
Rather than viewing the credentialing process as a professional hurdle instituted by a facility, an LIC will appreciate the review as more of a “partnership” between him/herself and the facility where the healthcare privileges are sought. No one – neither the credentialing professional nor the LIC – relishes bureaucratic steps and submission of voluminous documentation that have become the bane of applications. In the end, however, the process seeks to protect everyone involved in the safe delivery of healthcare services.
Look for additional credentialing issues to be highlighted in future publications, such as:
Do you scrutinize and monitor your credentialing contractor for quality and completeness, if such an agency is utilized?
What measurements has your facility instituted to monitor/assess the quality of healthcare services provided by your LICs?
If there is a concern you would like to see addressed on our site, send us an email. Your suggestions are welcome and encouraged!