Hospitals Benefit from CMS Privileging by Proxy Rule for Telemedicine Providers

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Gerald L. Johnson

By Gerald L. Johnson and Philip Feldstein

In May 2011 the Centers for Medicare & Medicaid Services (CMS) published a Final Rule revising the credentialing rules of telemedicine and teleradiology providers. These are activities where medical information is transferred through interactive audiovisual media for the purpose of providing a consultation, to conduct an examination or perform a remote medical procedure.

 

Philip Feldstein

An example would include services provided by a distant-site radiologist who in terprets a patient’s x-ray or CT scan and then communicates his or her assessment to the patient’s attending physician.


The final rule effective July 5, 2011 now states that hospitals contracting with these providers are able assume the credentialing of the off-site providers subject to certain safeguard requirements. The Joint Commission refers to this as “privileging by proxy” and occurs when one Joint Commission-accredited facility accepts the privileging decisions of another accredited facility for “distant-site” physicians and practitioners — those who provide telemedicine services.

Now that this ruling is approved, the Joint Commission will be required to enforce CMS requirements concerning the privileging of physicians and practitioners in accredited hospitals providing and receiving telemedicine services. CMS states in its explanation, Joint Commission-accredited hospitals are concerned about being able to meet the upcoming CMS privileging requirements, particularly small hospitals and critical access hospitals. CMS is now recognizing the problems for these facilities in the task of privileging perhaps hundreds of practitioners and physicians, and feels its current requirements are duplicative and burdensome in costs and time.

Therefore, the CMS policy changes reduce the burden of traditional credentialing and privileging processes for Medicare-participating hospitals, so that patients may continue to receive the benefits that telemedicine provides. The primary requirement would allow the governing body of a hospital, where patients receive telemedicine services, to grant privileges based on medical staff recommendations that rely on information provided by the distant-site hospital. This in effect allows privileging by proxy. However, the hospital would not be prevented from using its own appraisals or traditional means of privileging.
Within the final rule CMS is adding requirements for accountability.

Here are the basics:

A hospital choosing the less-burdensome option for privileging must ensure that the distant-site hospital is actually a Medicare-participating hospital.

The individual distant-site physician or practitioner is privileged at the distant-site hospital providing the telemedicine services and that the distant-site hospital provides a current list of the particular physician or practitioner’s privileges.
The individual distant-site physician or practitioner holds a license issued or recognized by the state in which the receiving hospital is located.

The receiving hospital must send the distant-site hospital internal review of the distant-site physician’s or practitioner’s performance of these privileges.

Reviews would include all adverse events that may result from the distant-site physician or practitioner’s telemedicine services and all complaints the hospital has received concerning the distant-site physician or practitioner.

Ultimately the benefits of this for small, rural and critical access hospitals are numerous. CMS states that the removal of unnecessary barriers to the use of telemedicine may enable patients to receive medically necessary interventions in a timelier manner. It may enhance patient follow-up in the management of chronic disease conditions.

These revisions will provide more flexibility to small hospitals with a limited supply of primary care and specialized providers. In certain instances, telemedicine may be a cost-effective alternative to traditional service delivery approaches and, most importantly, may improve patient outcomes and satisfaction.

Gerald L. Johnson, Ph.D., FACHE, FAHRA and FACCA is the Senior Vice President of Compliance and Recruiting for Foundation Radiology Group. He was instrumental in Foundation’s becoming the first multi-institutional, Joint Commission-accredited radiology group. Philip Feldstein is the Director of Marketing with Foundation Radiology Group and has experience working with over 100 hospitals and physician groups. He has also helped several facilities through the process of attaining and then promoting their Joint Commission Disease Specific Certification.

For more information about Foundation Radiology Group visit our website www.foundationradiologygroup.com or call us at (412) 223-2272.