Verification of Healthcare Affiliations — Is There a "Best Practice" Today?

Does your organization provide the “name, rank, serial number” type of verification to other organizations? How far back does your organization go in verification of previous hospital affiliations? Five years? Ten years? Back to completion of training — even if training occurred more than 20 years ago? Do you have a different standard for verification of hospital affiliations for locum tenens and telehealth providers? As you know - some of these providers have literally hundreds of affiliations.

One of the questions we should ask ourselves (and answer truthfully) is just how valuable is the information we receive from other hospitals (particularly when we get back the name, rank and serial number type of response)? Does this information really help in making decisions about appointment and clinical privileges? Because if this information isn’t providing value, we should be asking ourselves why we continue to do it. The Joint Commission standards do not require that all current/previous hospital affiliations be verified. Neither does CMS (Centers for Medicare & Medicaid Services).

What the Joint Commission does require is investigation of any discrepancies that occur during the credentialing process. So – for example, if a provider listed all of his current/previous hospital affiliations and then the organization received the National Practitioner Data Bank report which identified a hospital affiliation which the provider did not list, that would be a discrepancy that would need to be investigated and resolved.

A related issue is the difference between a professional (peer) reference and a confirmation of hospital affiliation. If an organization is seeking to validate that a provider was on the staff of a hospital during a specific period, a generic response (provided via a website) should suffice. If, however, the requesting organization really needs confirmation of competency, a peer reference is needed and it should be sent to a specific provider (ideally via email so that the provider can send his/her response electronically).

Background History

In years past hospitals typically responded to questionnaires about a provider’s affiliation, reputation, health status, etc. When I worked in a hospital and received these requests for information, I completed the portion of questionnaires that dealt with “facts” (staff status, type of privileges, etc.) and then the appropriate medical staff leader would complete the “peer” reference portion of the form (these questions usually related to the applicant’s current competency).

Practices changed when early NCQA credentialing standards required providers to have a hospital affiliation. Providers who never intended to practice in the hospital environment applied for membership/privileges in order to comply with NCQA credentialing standards and maintain their managed care contracts (this particular NCQA standard that required a hospital affiliation is no longer in effect and has not been for many years). Medical staff leaders would not (and could not) complete competency references for providers for whom they had no knowledge. So what did I do? What most organizations did in those days – I responded with a form letter that stated affirmatively that the provider had been (or was currently) on staff, the dates of affiliation and that the organization had not taken any disciplinary actions against the provider. Later on, these inquiries were automated and now it is common for an organization to direct queries to a website where this information can be obtained.

Current Practices

The current situation at many healthcare organizations is that there are many providers who have membership and/or privileges but do not regularly use the hospital for their patients (this is changing as some hospitals are tightening up their requirements for privileges and no longer grant privileges to providers who do not provide services in their environment). However, when providers apply somewhere else – or apply for reappointment – they list (as required by the majority of application forms that I see) all the hospitals where they have a current or past appointment. (It should be noted that some applications limit their queries related to hospital affiliations to the past 5 to 10 years.) Hospitals respond that providers are/were on staff and “in good standing” even when the providers in question may never have used the hospital for patients.

Credentialers often use the fact that a provider had an affiliation during a period of time – and received an affirmative response that the provider was on the staff and in good standing – to presume that the provider was not in “trouble” (i.e., not in jail, not in a substance abuse treatment facility, etc.). But – we all know that just because a provider was on staff at a facility, doesn’t necessarily mean that the hospital had any contact at all with the provider.

Recommendations Related to Hospital Affiliations – INITIAL APPOINTMENT

There are obviously many options for healthcare organizations related to verification of hospital affiliations. After much discussion and deliberation, here are my recommendations regarding requests for hospital affiliations (for initial appointment):

What to Ask:

• Request complete disclosure (or a minimum of 5-10 years) on the application form of all healthcare organizations where the applicant has held membership and/or clinical privileges (past and current). Personally – I believe that 5 years of history is sufficient, but I know that some organizations are uncomfortable with not obtaining a complete hospital affiliation history (and remember that just because you ask for all affiliations does not mean that you have to verify all of them). Dates and type of affiliation (active, courtesy, temporary, etc.) should be provided by the applicant. The applicant should be instructed to identify those organizations where there was a substantial volume of clinical activity – and the type of activity (admissions, procedures, consultations, etc.).
• Request that the applicant provide copies of his/her performance reports from his/her current organization(s). You may decide to require one from the current organization where the applicant has the most clinical activity. If there are not current affiliations, request a performance report from previous organization(s). Again, obtain from organizations with significant clinical activity. Reports from previous organizations should include data from the past 2 years – older reports won’t substantiate current clinical competency. When applicants are completing their applications online, there should be a way for the applicant to upload documents such as performance reports.

What to Verify:

• Hospital Affiliations
  Verify all affiliations for the past __ years (I recommend a range of 2 - 10 years). Many organizations go back 5 years and are satisfied that this provides sufficient information. Remember that most organizations now typically obtain information from background checks – a step that has been added to the scope of verifications within the past few years. Affiliations will be asked to provide the following information: Staff Category; Dates of Affiliation (month/year to month/year OR month/year to Current); Primary Specialty (i.e., Internal Medicine, Pediatrics, General Surgery, etc.). Ask if the applicant was/remains in “good standing” during his/her affiliation with the organization. Ask for the organization’s definition of “good standing” (note – there isn’t a universal definition of this term). Many of these affiliations will be able to be verified via Web sites.
  
  Note – what is being verified here is whether or not the applicant was where he/she said he/she was during specific periods of time.
• Peer References
  Request that a peer reference be obtained from the Department Chair or other knowledgeable providers from all affiliations that occurred during the past two years where the applicant had significant clinical activity. Note that if activity was significant, the applicant should have already provided you with his/her performance report from each facility. Also remember – it is the applicant’s responsibility to make sure that your organization receives all information necessary to make a decision.

What to Provide:

Now the situation is reversed. What should your organization provide when asked by another healthcare organization?

• Affiliations that ended more than two years ago: Provide information about whether or not the provider was a member of the medical staff, the applicant’s primary specialty, staff category, and whether or not the provider was in good standing (and provide your organization’s definition of “good standing”). This information can easily be provided via a Web site.
• Affiliations that are current or that occurred within the past two years: These will most likely be peer references that will be sent directly to the applicant’s department chair or other peer reference. Many of these references will be sent to department chairs electronically and can be responded to electronically, so the credentialing department/medical staff office will typically not have any involvement in responding to these requests. If a request for a peer reference is sent directly to the credentialing department without being directed to a specific person, the credentials department staff member will need to either respond in writing with information about dates on staff, specialty, etc., direct the requester to the Web site where this information can be obtained or ask the department chair to respond to the request. The credentials department staff member should never provide information about current clinical competence.

Special Circumstances:

What to ask and who to ask:

Credentialing a provider who has functioned in a locum tenens/contract position requires some new approaches. There may be hundreds of previous affiliations (even during the past 2-10 years). No one has the time of verify all these affiliations. However, most of these providers work for a contract organization. They are placed in healthcare facilities by the contract organization. Require that the contract organization provide you with a listing of all the placements that the provider has had with them – you’ll want the name of the healthcare organization, the dates worked at the healthcare organization, and the services provided (i.e., locum tenens as an anesthesiologist, teleradiology services, etc.). Make it known that the application will not be considered complete until the information is provided by and attested to by the contract organization.

We recommend that providers who are providing telehealth services in an organization be credentialed via “credentialing by proxy” and therefore no hospital affiliations would need to be checked.

What to verify: Many healthcare organizations have decided to verify some, but not all of these locum tenens/contract affiliations. They usually verify more recent affiliations at organizations where there was significant clinical activity. And – they will often make phone calls to these affiliations in order to obtain information about current competence as well as to validate the affiliation/clinical activity. Most often, these phone calls are made by a physician, although they don’t have to be. It is becoming more common for organizations to establish a number of queries that they will not exceed (for example, they will verify up to 10 affiliations).

The good news is that hospitals are taking a look at how and when they request information about providers as well as respond to requests for information. Many organizations take the position that providers who never/infrequently use the hospital for their patients are eligible for membership only – no privileges. When those hospitals receive requests for information, they are then able to respond that the provider has/had membership only with no privileges. The requesting hospital will then know that they will need to seek information about current clinical competency elsewhere.

The entire point of this article is to encourage healthcare organizations to think about what they verify (and what they provide to other organizations that request information). The goal is to ask for information that assists in making decisions that protect patients – and to avoid asking for information just because it has always been done that way in the past. Credentialing and privileging is more complex now than ever. Let’s make sure that the time we spend in gathering information is time well spent and doesn’t unnecessarily make credentialing more complicated and time-consuming without adding value.