Delegating Credentials to a CVO
There are many benefits to delegating credentialing to a qualified Credentials Verification Organization (CVO). However, this does not remove all responsibility from the delegating organization. There are many questions to be asked, issues to be resolved, and processes to be documented prior to delegating credentialing. When the following issues are resolved properly, the delegating organization will be confident they are onboarding providers that meet or exceed state and federal requirements.
One of the first considerations is Role Definition. The following points may seem apparent but unless they are documented and agreed to by both parties, it can lead to serious misunderstandings that may ultimately, be paid for by the delegating company. Therefore, the delegator must establish a policy and procedures manual including the following points:
Detailed list of responsibilities of each party
Description of delegated activities
Semi-annual or better reporting requirements
Delineated valuation process
Procedures for remediation or revocation of contract
Terms are mutually agreeable
Having these policies and procedure documented will avoid misconceptions and give clear definition of the agreed upon role of each party.
Know Where Responsibility Lies
While the delegating entity may give a delegate the authority to act on its behalf it still remains responsible and accountable for the performance of that activity.
Whether the functions are performed by a delegated CVO or in-house, the delegating company is ultimately accountable for all functions performed within its domain. The delegating organization must exhibit the ability to monitor the activities of its subcontractors as well as ensure that processes are performed according to standards, such as NCQA (National Committee for Quality Assurance).
The delegating organization should perform regular audits and share the results with the CVO. They should then work alongside one another to create a Corrective Action Plan (CAP) to remedy each issue revealed in the audits. All documentation should be saved and readily available for reference and audits.
Protected Health Information
It is critical to document if any protected health information (PHI) will be provided to the CVO. If this information is transferred, NCQA standards require the following provisions in the documentation:
List of allowed uses
Description of safeguards that will prevent misuse by the delegate
Delineation of any transfer to sub-delegates
Assurance that the delegate will afford individuals access to their PHI information
Established notification system if there is a breach in security or protocol when dealing with PHI
Agreement that all PHI will be returned or destroyed at the delegators request at the end of the contract
When the delegating organization properly handles these essential obligations, they can move forward with ease and peace of mind.
About Melissa Outlaw
Melissa Outlaw is a Vice President, Customer Success with symplr. Melissa and her team assist clients in learning and implementing our provider management software - credentialing, privileging, peer review, quality and event reporting applications. She supports clients in benchmarking current internal practices, identifying potential efficiencies, then driving the integration of technology with process improvement to reduce time of service and operating expenses. She works extensively with decentralized, multi-facility organizations in transitioning to a shared service center as well as assisting healthcare organizations bridge the gap between procedures performed by a provider and their privileges granted.