In a recent blog post, we introduced Rick Curtis as our speaker of the month to discuss the tips and traps of telemedicine concerning CMS requirements. Rick Curtis is the current CEO of the Center for Improvement in health Quality (CIHQ) and is a distinguished speaker on CMS certification process.
In Part 1, we touched upon the evolving definition of telemedicine and fundamental differences between distant hospitals and distant-site entities. In part two below, we review CMS requirements for written agreements and dive into more detail on the major nuances between distant-site entities and distant hospitals. While the differences between the two are functionally minor, they play a major role in the provisions that must be met to maintain your hospital’s CMS certification.
CMS Credentialing for Distant-site Entities and Distant Hospitals
With healthcare costs rising, and with an increased interest to make the credentialing process more efficient, CMS began permitting the use of a telemedicine service provider’s in-house credentialing. This was in place of a separate credentialing process through the service recipient. As long as there is a written agreement containing Code of Federal Regulations (CFR) 482.12(a)1 through (a)7, this eliminates a lot of redundant work.
Important Details of CFR 482.12(a)1 through (a)7
The foundation to the relationship between the telemedicine service provider and recipient is the written agreement. It holds the service provider accountable to the same credentialing standards as the recipient hospital, which means it maintains its CMS certification.
The CFR 482.12 regulations are an integral component of the written agreement. Sections (a)1 through (a)7 specifically outline the rights and perquisites needed for CMS to certify a governing body’s medical staff. These sections touch on four main points:
- Ensures that the practitioners in question are eligible for appointment to a medical staff in accordance to State law.
- Requires that the medical staff has bylaws.
- Ensures that the criteria for selection into the medical staff extend beyond certification, fellowship, or membership in a specialty body, taking into consideration the individual character, competence, training, experience and judgment of a candidate.
- Ensures that the medical staff is held legally accountable to the governing body for the quality of care provided to patients.
These four main points establish standards and incentives to achieve a higher quality of care. They also protect the practitioner or physician by giving them a voice in the governing body.
Warning: Specify Vague Credentials
Although CFR 482.12(a)1 through (a)7 allows a hospital to use the credentialing from a service provider, it is important for the hospital receiving services to ensure that all credentials cover exactly what the practitioner or physician is able to practice in detail.
For example, a teleradiologist may be given core privileges in teleradiology, allowing them to perform the core tasks of their role. However, within these core credentials are admittance privileges, which may be out of scope from what the teleradiologist is trained or capable of doing. This would violate CMS compliance. On record, you will have a teleradiologist who is capable of performing an admittance, but in reality it has put the patient at risk.
CMS Compliance Differences Between Distant Hospitals and Entities
Although distant hospitals and distant-site entities are two different business models, the CFR 482.12(a) through (a)7 regulations make many of the provisions standard practice. One example of this is the provision of needing to have a license to practice within the State that is receiving services. This provision requires evidence that the receiving hospital has performed an internal review of the quality of services provided by the telemedicine service provider’s physician or practitioner.
The overarching differences in provisions are due to the distant-site entity not being a Medicare participating hospital. Distant-site entities must also follow CFR 482.22 (a)1 through (a2), which adds two additional provisions to the written agreement which are unique to distant-site entities:
- The distant-site entity must provide a current list to the hospital receiving services of all practitioners and physicians covered by the written agreement, including their privileges at the distant-site entity.
- The hospital receiving services must provide evidence, with a written copy, of a review of the telemedicine practitioner or physician’s performance. This review includes all complaints and concerns about telemedicine performance. To remain compliant, it is recommended that a review be done every appointment cycle.
The CMS credentialing processes are meant to provide a higher-standard for healthcare quality. The standards help the Center for Medicare & Medicaid Services monitor the status of healthcare, providing more efficient credentialing to scale. However, they also come with many moving parts that need to be managed by the services recipient to remain compliant.
For more information about the tips and tricks to the telemedicine credentialing process, listen to our symplr education series webcast titled, “Telemedicine: Tips and Traps!” with Rick Curtis.
Maintaining CMS compliance to scale doesn’t have to be difficult. symplr offers easy-to-use credentialing solutions, freeing your healthcare system to perform other important tasks. To learn more about effective credentialing solutions, Schedule a Demo with symplr now!