Can anyone reasonably argue that possession of a current unlimited license to practice medicine or osteopathy verifies that the bearer has completed a recognized course of study in an acceptable accredited medical school and has competed at least one year of residency training?
Every state takes great pains to verify that applicants for licenses have completed medical or osteopathic school and have completed at least one (in some cases two) years of an accredited postgraduate residency program. Why then do regulatory and accreditation agencies require that all health care organizations confirm completion of medical school with a primary source? Why is it not permissible for these organizations to rely upon the state, which grants the license, for confirmation of completion of basic medical education? Perhaps the reason is nothing more than tradition.
Can anyone reasonably argue that certification by a board recognized by the American Board of Medical Specialties (ABMS) or the American Osteopathic Association (AOA) indicates that the bearer has completed a recognized and accredited post graduate residency training program, or has been found by that board to possess equivalent experience and competence?
Every ABMS or AOA certifying board goes to great lengths to verify that applicants have completed an approved residency program and meet other important requirements for certification.
Why then do regulatory and accreditation organizations require that all health care organizations confirm residency completion?
In fact, they do not. Completion of an approved residency is not required by any hospital accreditation program or by the Centers for Medicare and Medicaid Services (CMS) or by any state hospital licensing regulation or statute. Many hospitals and managed care organizations do have such a requirement and it should therefore be up to the organization to determine how it wishes to confirm residency completion.
Why don’t medical staffs rely upon board certification as verification of completion of residency training (or equivalent grandfathered activity)? Tradition! (And outdated standards.)
As acquisition of a National Practitioner Data Bank (NPDB) report is mandatory, and since such reports contain information that confirms education, training, licensure, federal and state sanctions/actions and malpractice settlements, why is it not reasonable to permit hospitals and others involved in credentialing to rely upon such federally supplied representations?
Why is it necessary to duplicate this effort by requiring primary confirmation of these issues?
That answer is easy—because NPDB regulations explicitly state that health care organizations may not rely upon such federally provided representation. Why this is so is probably the result of concerns about competition with other proprietary data banks. And tradition.
Can anyone reasonably argue that the presence of a Medicare provider number signifies that CMS has verified education, licensure, and freedom from federal sanctions?
In fact, CMS will not issue a provider number without an extensive application and review process that includes verification of medical education, license and freedom from sanctions.
Why then is it not permissible for hospitals to rely upon the presence of a CMS issued provider number to verify such basic credentials? Accreditation and CMS regulations, of course, but mostly tradition!
In today’s technological environment where information is readily available and is extremely accurate, it seems reasonable that the next revision of national credentialing standards would require the following:
- Acquisition of an NPDB report that may then be relied upon to confirm licensure actions, disciplinary actions, medical education, malpractice settlements, Drug Enforcement Administration (DEA) permit, etc.
- Confirmation of state license (which provides a second confirmation of professional school completion and, in many cases, provides significant additional information about the licensee.)
• If the applicant is certified by a recognized board, confirmation of this fact, which could then be relied upon as a third confirmation of successful completion of medical or osteopathic school, and residency completion or equivalence.
- Confirmation of the presence or absence of past criminal history (none of the above confirmations assure that the practitioner does not have a criminal record that would be of interest to the organization.)
- Confirmation of the ability to legally order certain medications, as shown by a DEA permit if this is not confirmed during one of the above checks (where needed.)
The above could be completed with a few strokes of the computer keyboard in a matter of hours, leaving the medical staff office time to gather information confirming current clinical competence, which undoubtedly is the most important step in the entire process.
Remember the competency equation: competency=actual practice + evidence that such practice is acceptable to peers and co-workers.
The following verifications are essential:
- Current, recently completed professional references from qualified peers or others.
- Verified recent volume data showing actual recent clinical practice (number and types of patients treated.)
- Relevant recent work history.
The following activities add no value and could safely be discontinued:
- Obtaining copies of documents such as license, certification certificate, diploma, etc.
- Contacting additional primary sources to confirm medical school or residency.
- Conducting a sanctions search of federal data banks.
- Contacting all past practice sites to confirm absence of disciplinary actions.
- Contacting all past affiliations to confirm presence.
- Contacting all past malpractice carriers to verify settlements. (Unless the staff is interested in the number of actual claims filed against a practitioner.)
No more digging to confirm medical education, residency completion, past licensure actions, all past practice affiliations, etc., needs to be done.
Regardless of how it is evaluated, the current process that hospitals use to verify qualifications and competency is archaic. The field seems, as a result of CMS and accreditation requirements, to be caught between a past that relied upon photocopies of documents and the use of snail mail and a future that promises to reveal nearly everything necessary to make informed decisions available with a stroke of the keyboard.
Many hope that the future is not distant, because the hospital and its medical staff have far more important jobs to do than needlessly chasing credentials that already have been subject to excellent vetting. Some, however, will stand in the way with their arms raised as if to stop the wave of change, for they see this change as disruptive of tradition.
This issue of the Digest features another of Dr. William Cors’ excellent articles on best practices in credentialing, this one about the factual reference. And our latest installment of “For MSPs Only” offers another savvy tip for improving communication skills.
That’s it for this month.