Who is an Allied Health Practitioner? Categories of AHPs. Licensed Independent Practitioners (LIPs)

Transcription

1 Who is an Allied Health Practitioner? Categories of AHPs Licensed Independent Practitioners Advanced Dependent Practitioners Dependent Practitioners Licensed Independent Practitioners (LIPs) Individuals who by license and hospital protocol are permitted to practice independently without supervision or direction. 1

2 Examples of LIPs Podiatrist Psychologist Social Worker Audiologist Dependent Practitioners (DPs) Individuals who practice under the supervision of a physician and are granted a scope of practice. Examples of DPs Scrub technician LPN RN (rounding) 2

3 Advanced Dependent Practitioners (ADPs) Individuals who practice under the supervision of a physician and are granted clinical privileges. Examples of ADPs Physician Assistant Advanced Practice Registered Nurse CRNA Midwife Question: What are the rules for AHPs? 3

4 The rules come from different sources: State licensing laws JC or AOA CMS Other Considerations: National Practitioner Data Bank and state reporting statutes HR policies and practices Question: What categories of AHPs should be allowed to practice in the hospital? 4

5 Absent an any willing provider or antidiscrimination statute, each hospital can decide which AHPs should practice. Decisions should be made based on best interest of patient care and mission of the hospital. Be careful. These decisions can have antitrust implications. 5

6 Keep individuals with competing economic interests out of the decisionmaking chain. Board must make the final decision. Question: What should AHPs be permitted to do in the hospital? 6

7 Review state licensing statute. Remember: hospital protocol may be more restrictive than licensing statute. Question: Should AHPs be granted clinical privileges or a scope of practice? 7

8 Joint Commission now requires that ADPs be granted clinical privileges. CMS also requires that ADPs be granted clinical privileges. DPs can be granted a scope of practice. 8

9 Question: Should AHPs be granted appointment? Medical Staff has duties and responsibilities: Attendance requirements ER call Committee responsibilities PI functions Question: What process should be used to credential, recredential and privilege AHPs? 9

10 LIPs JC and CMS treat all LIPs alike (including physicians). LIPs must be credentialed, recredentialed and privileged through the medical staff process MS process includes final action by the Board DPs LD.3.70 Single set of criteria must be used to judge competency of all clinicians who provide care, regardless of whether they are employed by the hospital or an LIP. 10

11 HR.1.20 EOP Qualifications and competence of non-employed DPs are assessed to determine if commensurate with similarly situated employed practitioners. Many hospitals continue to use HR or a hybrid process for processing DPs. ADPs According to the Joint Commission, PAs and APRNs may be privileged through the medical staff or an equivalent process. 11

12 ADPs CMS has rejected the equivalent process option. ADPs According to CMS, ADPs provide a medical level of care and must be credentialed through the medical staff process. Medical Staff Process Must include: Verification of education, training, licensure Verification of experience and ability to perform privileges (by peer reference) Assessment of core competencies 12

13 Medical Staff Process Must include: Department chair report on clinical privileges Recommendation by MEC Final action by Board Question: Should provisions pertaining to AHPs be incorporated into Medical Staff Bylaws? MSRRs often address issues such as who can write orders and when a physician is required to countersign orders. 13

14 Adopt AHP Policy to address the other issues pertaining to these practitioners. AHP policies could address: Process for assessing need Criteria for permission to practice Process for credentialing and privileging AHP policies could address: Change in privileges of supervising physician Responsibilities of supervising physician 14

15 AHP policies could address: Suspension or relinquishment of privileges or scope of practice Hearing and appeal process Question: Who oversees the credentialing of AHPs? Options: Medical Executive Committee Credentials Committee Allied Health Committee 15

16 Monitoring Performance of AHPs MS 3.10 requires MS leadership in measuring, assessing and improving processes that depend on activities of LIPs or other practitioners credentialed through MS process. This means Medical Staff must be involved in performance evaluation of LIPs and ADPs. Ongoing review should include: Review of procedures performed and their outcomes Pattern of pharmaceutical usage Requests for tests and procedures Morbidity and mortality data Use of consultations 16

17 Information may be acquired by: Periodic chart review Direct evaluation Monitoring of diagnostic and treatment techniques Discussion with other individuals involved in care Also consider: Patient and staff complaints Appropriateness and timeliness of H&Ps Appropriateness of orders Appropriateness of physician oversight DPs are not covered by this standard. 17

18 HR.1.20 EOP 12 Hospital reviews qualifications, performance and competence of DP at the same frequency as for similarly situated employed practitioners. If employed practitioners are assessed annually, DPs must be also. Evaluate same elements for employed and nonemployed DPs. 18

19 Use supervising physician as well as hospital supervisor to assist in evaluation. Best Practices in Supervision Consult state law. Question: How should significant concerns about AHPs be handled? 19

20 Have a process for immediate action. Outline investigative process. Hearing and appeal rights 20

21 MS 4.50 requires a mechanism for a hearing and appeal for adverse decisions pertaining to privileges. Hearing and appeal may be different for AHPs and members of the Medical Staff. Hearing and Appeal Options for LIPs and ADPs Same process as for medical staff members Less formal process that meets elements of HCQIA Streamlined hearing process that doesn't meet elements of HCQIA 21