Telehealth Credentialing and Privileging

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New CMS Rules on Telemedicine Credentialing & Privileging

View an interactive learning module on Credentialing and Privileging

3 Options for C&P

  1. Full credentialing by providing site (traditional)
  2. Reliance on distant site Medicare-certified hospital
  3. Reliance on distant site telemedicine entity

3 types of scenarios Requirements (prior to July 5, 2011)

  1. Providing Site must have a credentialing and privileging process for ALL physicians and practitioners, including telemedicine practitioners.
  2. Requires a hospital’s medical staff to grant privileges even where a provider is not “on-site”.
  3. Duplicative and burdensome process

New Rule (Not Required) (after July 5, 2011)

Hospitals and critical access hospitals may implement new credentialing and privileging processes for telemedicine practitioners by relying on the credentialing and privileging of such telemedicine practitioners by the “Distant Site” provider. Defines telemedicine as “provision of clinical services to patients by practitioners from a distance via electronic communications”. Not necessarily real time under this definition. Distinction between informal consultations and professional consultations. Curb Side Consults vs. Formal Consult with medical diagnosis.

Who can be a “Distant Site”?

  • Medicare participating hospitals providing telemedicine services
  • Non-medicare participating hospitals providing telemedicine services so long as they enable a providing site to meet the conditions of participation
  • Other telemedicine entities providing telemedicine services so long as they enable the providing site to meet the conditions of participation.

Who can be a “Providing Site”?

  • Any Medicare-participating hospitals, regardless of facility size or location.
  • Any Medicare-participating Critical Access Hospital, regardless of facility size or location.
  • Rural health clinics or federally qualified health clinics(FQHC’s) are not included – Subject to separate Medicare conditions for Coverage.

A providing site does not have to rely on a distant site for C & P. The Written Agreement

  • To rely you need a written agreement between the providing site and the distant site.
  • A detailed written agreement is required to be in place if a Providing Site is to rely on the Distant Site’s C & P of its telemedicine provider.
  • Written agreement will be requested for review during “survey process”.
  • Written agreements in place with “distant site” while using traditional C&P process are not required to contain all of these elements.

Elements of the Agreement

  • Specify that “governing body” of the distant site must meet the existing Medicare Conditions of Participations
  • Distant Sites that are not Medicare participating hospitals, must also ensure that the telemedicine services are provided in a safe and effective manner consistent with the Provider Site’s policies and standards.
  • Evidence of telemedicine practitioner’s privileges (Make clear what privileges are granted through this written agreement.)
  • State based licensure requirements or telemedicine requirements still apply
  • National Practitioner Data Bank requirements for querying still apply
  • Evidence of internal review of telemedicine practitioner’s performance by Distant Site. Provider has to report periodically (including adverse events, complaints) to Distant Site. Be aware of state disclosure/privacy requirements.
  • Indemnification/Risk Sharing considerations
  • Subcontracting for telemedicine services may necessitate additional provisions and diligence. (Cannot require C&P to come from distant site)