Credentialing Resource Center Journal

Credentialing Resource Center Journal P4 P7 P9 Cutting through more CoP confusion Michael Callahan, Esq., answers a range of questions regarding CMS revisions that affect MSPs, from medical staff unification to new requirements for direct consultation. Privileges for allergists/ immunologists Specialists on the front lines of allergy and immunology care and treatment got there through a variety of educational and practice channels. New technology, new opportunities and challenges Carol Cairns, CPMSM, CPCS, talks about the evolution of credentialing and privileging through the years, and what CRC Symposium attendees can look forward to. Volume 24 Issue No. 2 FEBRURY 2015 P12 The MSP s voice voiding risk and the unknown are part of MSPs valuable talents, but Rosemary Dragon, CPMSM, CPCS, says it s important to understand the upside of necessary change. CMS CoPs If you're considering privileges for dietitians, check state laws CMS 2014 final rule clarified its position that categories of non-physician practitioners could be included on the medical staff; it also enabled medical staffs to privilege registered dietitians (RD) and other nutrition professionals to order therapeutic patient diets. However, these changes and subsequent interpretation continue to serve up confusion as hospitals prepare for CMS surveys in 2015. Revisions in the 2014 Hospital Conditions of Participation (CoP) allow certain non-physician practitioners, including RDs, when determined to be eligible for appointment by the governing body, to have privileges like other medical staff members. The revisions also permit RDs and other clinically qualified nutrition professionals to be privileged to order therapeutic patient diets under the Hospital CoPs. The major questions are whether non-physician practitioners should be granted medical staff privileges and membership, or hold privileges without becoming medical staff members. nd if hospitals opt to privilege RDs but not add them to the medical staff, who would be in charge of the privileging process and how would it function? nswers will vary among organizations, and any decision must take into account the state requirements for RDs and nutrition professionals. CLINICL PRIVILEGE WHITE PPERS We are constantly updating our library of Clinical Privilege White Papers. Here are a few of the most recently updated papers: Hospital pharmacist Practice area 183 llergy and immunology Practice area 124 Optometrist Practice area 168 Dermatology Practice area 132 Registered nurse first assistant Practice area 183 Download the latest papers from www.credentialingresourcecenter.com.

Credentialing Resource Center Journal February 2015 482.28 (b)(1) and (2) were revised to permit a qualified dietitian or qualified nutrition professional to order diets if authorized by the medical staff and in accordance with State law governing dietitians and nutrition professionals. This includes therapeutic diet ordering. This means ordering of diets is no longer restricted to practitioners responsible for the care of the patient, a recent CMS Survey and Certification letter states. Hospitals may appoint RDs to the medical staff and grant them specific nutritional ordering privileges, or authorize the ordering privileges without appointment to the medical staff, through the hospital s appropriate medical staff rules, regulations, and bylaws, according to the Interpretive Guidelines. Under CMS 482.28(b)(1), enacted in 2008, therapeutic diets must be prescribed by the practitioner(s) responsible for the care of the patient. CMS Interpretive Guidelines for 482.28(b)(1) stated at the time that therapeutic diets had to be prescribed in writing by the practitioner responsible for the patient s care, documented in the patient s medical record, and evaluated for nutritional adequacy. In accordance with State law and hospital policy, a dietitian may assess a patient s nutritional needs and provide recommendations or consultations for patients, but the patient s diet must be prescribed by the practitioner responsible for the patient s care, the 2008 Guidelines stated. However, in the final rule issued in May 2014, CMS revised 42 CFR 482.28(b)(2) to stipulate that patient diets were to be ordered by a practitioner responsible for the care of the patient, or by a qualified dietitian or qualified nutrition professional as authorized by the medical staff and in accordance with state law governing dieticians and nutrition professionals. Employee or medical staff member? Hospitals have long employed nutrition professionals, but not as members of the medical staff: Physicians can and do change patient diet orders themselves, explains Kathy Matzka, CPMSM, CPCS, a medical staff consultant in Lebanon, Illinois, and member of the CRCJ Editorial dvisory Board. However, if an RD or nutrition professional can initiate or change diet orders without the physician having to sign off, that person must be granted privileges to do so, she says. Until last year s revisions, CMS cited RDs and nutrition specialists as examples of non-physicians who This document contains privileged, copyrighted information. If you have not purchased it or are not otherwise entitled to it by agreement with HCPro, a division of BLR, any use, disclosure, forwarding, copying, or other communication of the contents is prohibited without permission. EDITORIL DVISORY BORD Product Manager, Digital Solutions drienne Trivers Follow Us Follow and chat with us about all things healthcare compliance, management, and reimbursement. @HCPro_Inc Managing Editor Mary Stevens mstevens@hcpro.com Carol S. Cairns, CPMSM, CPCS Senior Consultant The Greeley Company Danvers, Massachusetts President PRO-CON Plainfield, Illinois Becky Cochran, CPMSM, CPCS Director of Medical Staff Services San Juan Regional Medical Center Farmington, New Mexico Christina W. Giles, CPMSM, MS Independent Consultant, Medical Staff dministration Nashua, New Hampshire Kathy Matzka, CPMSM, CPCS Medical Staff Consultant Lebanon, Illinois Robert W. McCann, Esq. Partner Drinker Biddle & Reath, LLP Washington, D.C. Maggie Palmer, MS, CPMSM, CPCS, FCHE National Director of Credentialing Tenet Healthcare Dallas, Texas Sheri Patterson, CPCS President MSO Staffing Telecommuting Solutions Newport, Oregon Sally J. Pelletier, CPMSM, CPCS dvisory Consultant, Chief Credentialing Officer The Greeley Company Danvers, Massachusetts nne Roberts, CPMSM, CPCS Senior Director, Medical ffairs Children s Medical Center Dallas, Texas Elizabeth Libby Snelson, JD Legal Counsel to the Medical Staff St. Paul, Minnesota Fatema Zanzi, Esq. ssociate Drinker Biddle & Reath, LLP Chicago, Illinois Credentialing Resource Center Journal (ISSN: 1076-5980 [print]; 1937-7339 [online]), the newsletter of the Credentialing Resource Center (CRC), is published monthly by HCPro, a division of BLR. Enrollment fee in the CRC is $499/year or $899/two years. Credentialing Resource Center Journal, 100 Winners Circle, Suite 300, Brentwood, TN 37027. Copyright 2015 HCPro, a division of BLR. ll rights reserved. Printed in the US. Except where specifically encouraged, no part of this publication may be reproduced, in any form or by any means, without prior written consent of HCPro or the Copyright Clearance Center at 978-750-8400. Please notify us immediately if you have received an unauthorized copy. For editorial comments or questions, call 781-639-1872 or fax 781-639-7857. For renewal or subscription information, call customer service at 800-650- 6787, fax 800-639-8511, or email customerservice@hcpro.com. Visit our website at www.hcpro.com. Occasionally, we make our subscriber list available to selected companies/vendors. If you do not wish to be included on this mailing list, please write to the marketing department at the address above. Opinions expressed are not necessarily those of CRCJ. Mention of products and services does not constitute endorsement. dvice given is general, and readers should consult professional counsel for specific legal, ethical, or clinical questions. 2 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.

February 2015 Credentialing Resource Center Journal could potentially be appointed to the medical staff. The May 2014 changes in the rule allow RDs to be granted privileges for ordering patient diets, including therapeutic diets, she says. Some of the confusion originates in whether an organization s process for granting privileges makes RDs and other providers members of the medical staff. CMS Interpretive Guidelines also state that for nonphysician practitioners granted privileges only, the hospital governing body and medical staff must exercise oversight, such as through credentialing and competency review, just as it would for practitioners who are members of the medical staff. If an organization decides to grant privileges to nonphysicians, then the evaluation and oversight of the medical staff is required, says Matzka. That means RDs and nutrition professionals would be subject to FPPE and OPPE in Joint Commission and now HFP-accredited organizations, as are other members of the medical staff. Check state laws first The first step in any move regarding privileges for RDs should be to check applicable state laws. In many cases, state law determines the scope of practice for RDs, and many states restrict RDs ability to order independently. s with advanced practice professionals, hospitals must be aware of any restrictions that exist. In Illinois, for example, dietitians can only initiate diet orders by or in conjunction with the physician who s licensed and acting within the scope of his or her practice. I interpret that to mean the dietitians in Illinois still have to have a consultation with a licensed physician in order to be able to write those diet orders, Matzka says. In states that allow independent ordering, Matzka suggests that organizations credential RDs and nutrition professionals through the human resources department to avoid process duplication. For example, a hospital could hire the RD as a hospital employee through HR, but have the medical staff review the file through the credentialing and privileging process. This would enable the RD to initiate diet orders without being on the medical staff, and would also demonstrate that the medical staff was exercising oversight as required for compliance with the CMS CoPs, she says. For some facilities, the process may be the same for RDs as for other nonphysician hospital employees performing a medical level of service. For example, if a registered surgical nurse assistant is working in the OR, and he or she performs suturing, that procedure meets the definition of surgery under the merican College of Surgery Guidelines, which is what CMS follows. So the registered nurse assistant must be privileged to perform suturing, but need not be on the medical staff, nor be processed through the medical staff process, Matzka says. Rather, the HR documentation can be taken through the medical staff approval process and they can be granted privileges to [suture]. Certification and credentials To earn the cademy for Nutrition and Dietetics RD certification, applicants must: Complete a bachelor s degree at an accredited U.S. university or college, including coursework accredited or approved by the ccreditation Council for Education in Nutrition and Dietetics (CEND) of the cademy of Nutrition and Dietetics. Complete an CEND-accredited supervised practice program at a healthcare facility, community agency, or a foodservice corporation or combined with undergraduate or graduate studies. Typically, a practice program will run six to 12 months in length. Pass a national examination administered by the Commission on Dietetic Registration (CDR). Complete continuing education requirements to maintain registration. The academy offers a registered dietitian nutritionist (RDN) credential in addition to RN certification. The RDN credential does not affect licensure or other regulations, and many state licensure/certification laws already reference the term nutritionist, according to the academy s website. RDs can hold additional certification in specialized areas of practice, including pediatric or renal nutrition, sports dietetics, nutrition support, and diabetes education. These certifications are awarded through CDR, the credentialing agency for the academy. Other medical 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400. HCPRO.COM 3

Credentialing Resource Center Journal February 2015 and nutrition organizations are recognized within the profession as well. The Joint Commission and CMS standards require hospitals to employee a credentialed (and licensed, if applicable) dietitian. State requirements are frequently met through the education and training required to become an RD, according to the academy. In a hospital setting, dietitians provide detailed assessments on patients nutritional status, their calorie and protein needs; and how to best meet their nutritional requirements, according to Lisa Cimperman, MS, RDN, LD, clinical dietitian at University Hospitals Case Medical Center in Cleveland. We provide recommendations on the most appropriate diet and also provide education. Some patients require even more specialized nutrition support in the form of enteral or parenteral nutrition, she says. In this case, dietitians assess the patients needs, provide appropriate recommendations for the physician, and follow [patients] closely to ensure good tolerance to the feeding regimen. If the CMS revisions will allow dietitians to write orders for diet when permitted by state law, this certainly will change our role and responsibilities in the hospital, Cimperman says. The thing that needs to be done now is individual institutions, [including] University Hospital Case Medical Center, need to come up with a policy regarding order-writing privileges for dietitians. The enteral piece is one of the things that hasn t been fully discussed in the rule, so I ll be interested to see what other places do with that. RDs attain at least a bachelor s degree and potentially masters internship, and sit for an exam, so any RD should be able to order an appropriate diet for a patient, she says. In addition, Cimperman says some institutions might be expected to require one year of experience in a particular setting as part of their privileging criteria; this is because learning how a health system s particular systems work and figuring out how the physicians function will vary from organization to organization. lthough the revised CMS language may be confusing when it comes to medical staff membership and privileges for RDs, ultimately the changes will be good for patients, according to Cimperman. Dietitians are the professionals who are most focused on the patient s nutrition, she says. I think to have us driving the order may help get the most appropriate diet ordered for the patient, and may help the patient get that [diet] sooner rather than later. Matzka suggests hospitals take a wait-and-see approach. My advice is, do not start putting people on the medical staff until we see how this is going to pan out. It doesn t make a lot of sense to have people on the medical staff, filling out applications and so forth, if they re hospital employees. You re duplicating the whole process that you would do through HR. But the medical staff does need to grant privileges and provide oversight, she says. I recommend that clients who have a registered dietitian or nutrition professional on staff, if their state regulations allow RDs to make independent decisions, then that would be when you would grant them privileges. H & Make sure medical staff members are informed of unification options and document it Thinking of implementing a unified, integrated medical staff across your healthcare system? The journey may start with a close look at your state regulations, says Michael R. Callahan, Esq., senior partner in the healthcare practice of Katten Muchin Rosenman, LLP, in Chicago. Callahan answered a variety of questions about CMS final medical staff rules during a recent webcast. To order this presentation on 4 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.

February 2015 Credentialing Resource Center Journal demand, go to www.hcmarketplace.com/final-cmscops-navigating-revised-medical-staff-standardsand-new-requirements. Our system has one governing board for a multihospital system and an advisory board at each hospital. Which board must meet the CMS requirement for direct consultation with the individual who is assigned the responsibility for the organization and conduct of the medical staff? The primary responsibility rests with the governing board. However, the CMS guidance allows this responsibility to be delegated to a board committee. Under the circumstances you describe, your advisory board at each hospital is probably a better choice, given its ongoing interaction with the medical staff. But it would be important, if not required, that at least one member of the advisory board also serve on the governing board in order to satisfy the requirement of a direct communication between the board and each medical staff. If this responsibility is being delegated by the governing body, I would recommend that an appropriate board resolution or similar record be made to reflect this decision and the basis for doing so. We have a committee of the board (a joint conference committee) that includes board members, medical staff leaders, and executive hospital leaders. They discuss medical staff issues including bylaws, credentialing, privileging, etc. The full board gets monthly reports that are approved as part of their consent agenda. Would this meet the direct consultation requirement? The answer will depend on whether you are a single, stand-alone hospital or are a multihospital system. joint conference committee historically was utilized to address disputes or concerns by and between the medical staff and hospital management or the board. CMS requires that direct communications relate to the quality of patient care provided at the hospital, such as specific population needs, development of performance improvement standards, etc. If the joint conference committee addresses such hospital-specific issues, then use of this committee will meet the direct consultation requirement as long as the committee includes the president of the medical staff as one of its members or it directly meets with this individual when these patient care issues are discussed. gain, these consultations must occur at least twice a year, and the details of what was discussed and how the issues are being addressed must be documented. The answer is more complicated when a multihospital system is involved. The answer provided in the previous question would apply here, except the hospital would be utilizing a joint conference committee instead of a local advisory board or other board committee. If any board committee is being utilized, it needs to have a direct meeting with or include as a member the chief or president of each medical staff in the system, and the patient care issues unique to each hospital must be addressed and documented. We have a question about the rule that covers ordering of outpatient services: If outpatient services must be ordered by a practitioner who is licensed in the state where he or she provides care to the patient, and is acting within his or her scope of practice under that state law, do we need to verify that the ordering practitioner is acting within his or her scope of practice under our state law, or the law for the state in which they are licensed? Both. For example, if a physician can order an outpatient service in Illinois, but for some reason is not permitted to order the service in the state where the service is to be provided, then the hospital is not allowed to carry out the request. Every state is different, and so you really have to check with state law. With regard to the decision to opt in or out of a unified, integrated medical staff, our bylaws say that only active medical staff members have a vote. Does this mean we need a revision to allow other categories of medical staff to vote as well? No. The CMS final rule is a little confusing on that point, but when you look to the guidance, our 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400. HCPRO.COM 5

Credentialing Resource Center Journal February 2015 interpretation is whoever has voting rights under your bylaws are the ones who can vote to opt in or opt out. It is fairly common that active staff members are the only ones who can vote. Courtesy staff members, for example, typically do not have voting rights. Under the new CMS standards, telemedicine physicians cannot vote, even if doing so is permitted under the bylaws. But the CMS guidance also acknowledges that this is an important question. Therefore, if you want to revise the process to allow other categories to vote, aside from telemedicine, you are free to do so. s a general rule, you follow your bylaws and the standard applied to quorums and approving an amendment. Once you are a member of the unified medical staff, how would you decide who would be eligible to vote if an individual hospital wanted to opt out? First, unified medical staff members have to be advised of their right to opt in and opt out. Second, you will have to implement a process in your bylaws for who puts this vote on the agenda and how. Can it be a recommendation from the bylaws committee? Can a petition signed by 20 physicians be enough to get the issue on the agenda for a vote? The hospital and medical staff have to agree on the process and then include this into the opt in/opt out provisions. The guidance only says that you cannot create inordinate obstacles such as requiring a petition signed by all voting medical staff members. gain, CMS defers to the hospital and medical staff as to how the vote gets on the agenda. When is the deadline for changing the language of bylaws to include opt in or opt out? It depends. Stand-alone hospitals do not have to amend their bylaws to include this provision. If, however, a hospital affiliates, merges, or otherwise becomes part of a multihospital system, it is required to initiate the process of amending the bylaws within six months after the closing date. For a multihospital system, the opt-in/opt-out provision must have been in the bylaws by December 31, 2014. If the provision was not finalized by then, hopefully the hospital will have initiated the amendment process before that date. In a state that does not allow an integrated, unified medical staff, must the medical staff bylaws be amended to provide for opt in/opt out? I would say no. My argument would be why include this option in the bylaws if it is clear that the state does not permit it? I have looked at commentary from attorneys who have cited provisions within state statutes that would suggest a unified medical staff is not permitted. However, the reality is, particularly if it is an older statute, no one really envisioned all the consolidations that have been taking place. Language in the state statutes may suggest that you could not have a unified, integrated medical staff in a multihospital system, but if it is not crystal clear, people may be reading too much into the supposed restriction. You should consult legal counsel to review applicable state laws. If people are comfortable that state law does not permit an integrated, unified medical staff, you would want to document this conclusion. nd where the language is ambiguous, sometimes it depends on what answer you want. Some state attorneys general will issue advisory opinions interpreting particular state statutes, so that is an option to consider. But if it is clearly not permitted, I would say you do not need to amend your bylaws at least for facilities in that state. If it is a multihospital system in different states, in other states where it is not prohibited, each hospital there would have to amend the bylaws. Can you clarify if the board of a multihospital system first needs to vote to move forward on an integrated medical staff; then, if approved, the process is drafted for the medical staff to vote to opt in or out? Yes. The common governing board must first approve the decision to recommend to all medical staffs that a unified medical staff be established as well as to document that a unified staff is permitted under the laws of each state where the hospitals are located. If not already prepared, the process or bylaw 6 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.

February 2015 provision for opting in (or staying separate) then needs to be followed. Keep in mind that the decision to opt in, stay separate, or opt out remains with each medical staff. The board cannot force the medical staffs to create a single unified staff. dditionally, it cannot prohibit a medical staff from opting out. Regarding the requirement for notifying medical staff members of their right to opt in/opt out: Does this mean once opt-in is approved by medical staff, we have to notify them every two years that they can reverse that vote? No. You have to advise every voting member, and probably every member, of the right of voting members of medical staff to opt in or opt out of a single unified staff. There has to be some notice in writing in their credentials files, so you can demonstrate compliance with the CMS notice requirement. The rule then says the ability to vote on whether to opt in or opt out at each medical staff has to take place at least once every two years. If the medical staff wants to do it every six months, that is up to them. Credentialing Resource Center Journal Would a bylaws attestation signed by the medical staff member in a reappointment application serve as documentation of notice in the credentialing file? CMS does not say what form of documentation is required. n attestation in the reappointment application is probably fine, as long as you can demonstrate that physicians were truly informed about this option. If you are burying the notice in some lengthy form or it is just a check box, I suppose that works, but I suggest you make sure the language is very clear or to even print in bold letters. Does the final rule apply to accountable care organizations (CO) i.e., a hospital that has an outpatient surgery center or primary care clinics? The rule only applies to hospitals. n CO is another name for a clinically integrated network that has multiple provider boxes, depending on how it is structured, including hospitals and other facilities. H Privileging Training varies widely, as does practice, for specialists in allergy/immunology Editor s note: HCPro s Credentialing Resource Center is constantly adding to and updating its library of Clinical Privilege White Papers, which outline sample privileging criteria and background research for a wide range of medical specialty and subspecialty areas, procedures, and allied health practice areas. Following is an excerpt from the newly updated Clinical Privilege White Paper for allergists and immunologists Practice area 124. n allergist/immunologist is a physician who, after completing medical school, has completed three years of training to become either a pediatrician or an internist, followed by a two-year (or longer) fellowship in allergy and immunology. ccording to the merican cademy of llergy, sthma & Immunology (I), allergists/immunologists are trained in the prevention, diagnosis, and treatment of immune system problems such as allergies, asthma, inherited immunodeficiency diseases, and autoimmune diseases. When a patient is referred to an allergist/immunologist, the physician works to diagnose the condition by taking a thorough history of the patient, including information about the patient s illness, family history, and home and work environments. Physicians in this specialty may also conduct allergy skin testing. To help prevent future symptoms, they can additionally create management plans to assist patients in controlling their environment. 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400. HCPRO.COM 7

Credentialing Resource Center Journal February 2015 The I states that allergists/immunologists treat problems related to and/or conduct research about the following: Skin disorders, including atopic dermatitis (eczema), urticaria (hives), and contact dermatitis dverse reactions to drugs, other pharmacologic agents, and diagnostic testing materials Immunogenetics Gastrointestinal disorders caused by immune responses to foods Diseases associated with autoimmune responses, including arthritis Stem cell, bone marrow, and organ transplantation Diseases of the respiratory tract, such as allergic rhinitis (hay fever), sinusitis, asthma, and hypersensitivity pneumonitis For more information, please see the following Clinical Privilege White Papers: Practice area 132 Dermatology Practice area 135 Internal medicine Practice area 152 Pediatrics Practice area 440 Physician assistants in allergy and immunology Positions of specialty boards BPS The BPS is an independent certification agency of merican Pharmacists ssociation (Ph). The BPS grants certification and recertification in eight practice specialties: mbulatory care pharmacy Critical care pharmacy Nuclear pharmacy Nutritional pharmacy Oncology pharmacy Pediatric pharmacy Pharmacotherapy Psychiatric pharmacy ll certification applicants must have graduated from a pharmacy program accredited by the CPE or equivalent international program, and must maintain an active license. Positions of societies, academies, colleges, and associations NBP The National ssociation of Boards of Pharmacy oversees all 50 state boards of pharmacy. lthough each state has its own requirements for licensure, state boards operate under the NBP Constitution and Bylaws, which direct the operations and activities of its members. SHP The merican Society of Health-System Pharmacists (SHP) offers various guidelines and policy papers concerning hospital pharmacists and the care they provide. In 2012, SHP updated its guideline document Minimum Standard for Pharmacies in Hospitals. ccording to the document, pharmacists should be concerned with not only the provisions but the outcomes of pharmacy services. Elements of pharmacy services include: Practice management Medication-use policy development Optimizing medication therapy Drug procurement and inventory management Preparing, packaging, and labeling medications Medication delivery Monitoring medication use Evaluating efficacy of medication use systems Research CRC draft criteria The following draft criteria are intended to serve solely as a starting point for the development of an institution s policy regarding this specialty. The core privileges and accompanying procedure list are not meant to be all-encompassing. They define the types of activities, procedures, and privileges that the majority of practitioners in this specialty perform. dditionally, it cannot be expected or required that allergy and immunology practitioners perform every procedure listed. Instruct practitioners that they may strike through or delete any procedures they do not wish to request. Minimum threshold criteria for requesting privileges in allergy and immunology Basic education: MD or DO 8 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.

February 2015 Credentialing Resource Center Journal Minimal formal training: Successful completion of an CGME- or merican Osteopathic ssociation (O)- accredited residency program in internal medicine or pediatrics, followed by an accredited fellowship training program in allergy/immunology ND/OR Current certification or board eligibility (with achievement of certification within [n] years) leading to certification in allergy/immunology by the merican Board of llergy and Immunology or subspecialty certification in allergy and immunology by the merican College of Osteopathic Internists/merican Osteopathic Board of Internal Medicine Required current experience: llergy/immunology services reflective of the scope of privileges requested to [n] inpatients or outpatients during the past 12 months, or successful completion of an CGME- or O-accredited residency or clinical fellowship within the past 12 months References If the applicant is recently trained, a letter of reference should come from the director of the applicant s training program. lternatively, a letter of reference may come from the applicable department chair and/or clinical service chief at the facility where the applicant most recently practiced. Core privileges in allergy and immunology Core privileges for allergy and immunology include the ability to admit, evaluate, diagnose, consult, manage, and provide therapy and treatment for patients of all ages presenting with conditions or disorders involving the immune system, both acquired and congenital. Selected examples of such conditions include anaphylaxis, asthma, contact dermatitis, eczema/atopic dermatitis, sinusitis, rhinitis, and urticaria; adverse reactions to drugs, foods, and insect stings; immune deficiency diseases (both acquired and congenital); defects in host defense; and problems related to autoimmune disease, organ transplantation, or malignancies of the immune system. Physicians may provide care to patients in the intensive care setting in conformance with unit policies. They may assess, stabilize, and determine disposition of patients with emergent conditions consistent with medical staff policy regarding emergency and consultative call services. Core procedures in this specialty include but are not limited to: llergen immunotherapy llergy testing, including blood (RST) testing and prick testing Delayed hypersensitivity skin testing Drug desensitization and challenge Drug testing Exercise challenge testing Food challenge testing Immediate hypersensitivity skin testing Intravenous immunoglobulin treatment and administration Methacholine challenge testing Nasal cytology Oral challenge testing Patch testing Performance and interpretation of pulmonary function tests Performance of history and physical exam Physical urticaria testing Provocation testing for hyper-reactive airways Rhinolaryngoscopy Reappointment To be eligible for renewal of privileges in allergy and immunology, the applicant must meet the following criteria: [Maintenance of certification is required.] Current demonstrated competence in allergy and immunology and adequate volume of experience ([n] inpatients or outpatients) with acceptable results, reflective of the scope of privileges requested for the past 24 months based on results of ongoing professional practice evaluation and outcomes. Evidence of current physical and mental ability to perform privileges requested is required of all applicants for renewal of privileges. In addition, continuing medical education related to allergy and immunology should be required. 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400. HCPRO.COM 9

Credentialing Resource Center Journal February 2015 Perspective The more credentialing changes One of the Credentialing Resource Center Symposium's presentations is titled Verify and Comply, and it includes some of the content from the sixth edition of the book by the same name. Carol Cairns, CPMSM, CPCS, author of the book and a panelist at the symposium, recently spoke about what attendees can expect from this in-depth, two-day event. Your book Verify and Comply is now in its sixth edition and some of the challenges you address in the book will also be discussed in the symposium. What are the biggest changes you ve seen in credentialing and verification processes in the past decade? There have been a number of significant changes within the industry. mong them are: The increase in negligent credentialing cases The increasing number of employed physicians has created role confusion and an added level of complexity in managing practitioner performance issues i.e., use of the traditional medical staff route and/or the human resources route The routes to achieving deemed status that hospitals now have in addition to CMS and The Joint Commission (i.e., HFP and DNV-GL) The increasing number of credentials verification requirements The emphasis on data-driven decisions and requiring evidence of practitioner competence The expanding scope of practice and privileges requested, as well as the increase among the clinical disciplines/specialties requesting these privileges The widening electronic management of credentials verification and data Will the Verify and Comply presentation at the CRC Symposium take a closer look at some of these changes? Yes, [fellow presenters] Sally Pelletier, CPMSM, CPCS; Hugh Greeley; Todd Sagin, MD, JD; and I will talk about almost all of these changes and the issues associated with them, and what medical staff leaders and MSPs can do to stay sane. It seems like every day brings new issues and challenges to the medical staff office, as you mentioned earlier. But are the underlying challenges to credentials verification processes the same now as they always were? Some are new, but some are not. For example, new and improved technology allows for automated verification of some credentialing elements. However, [it has also] increased emphasis on datadriven decisions, and requiring evidence of practitioners current competence on an ongoing basis and at renewal of privileges continues to be a struggle. The event will cover a lot of ground in two days. What insights or takeaways do you hope to offer to CRC Symposium attendees? Here are five things I hope our attendees take with them: How to avoid negligent credentialing through careful management of temporary and locum tenens privileges How to ensure professional references confirm current competence Identification of additional accreditation organizations available to acute and critical access hospitals How to manage the expanding roles of advanced practice professionals How to determine if your organization is responsible for privileging practitioners in the ambulatory sites of the organization EDITOR S NOTE See p. 11 for a sample of the symposium agenda. For more information about the CRC Symposium or to reserve your seat, visit www.hcmarketplace.com/the-credentialingresource-center-symposium. To find more about Verify and Comply: Credentialing and Medical Staff Standards Crosswalk, Sixth Edition, visit www.hcmarketplace.com/verifyand-comply-credentialing-and-medical-staff-standards-crosswalk-sixth-edition. 10 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.

February 2015 Credentialing Resource Center Journal Join us in March for the CRC Symposium! Register today for the CRC Symposium, March 12 and 13, at Caesar s Palace in Las Vegas Get your toughest credentialing, privileging, and medical staff leadership questions answered by industry experts Carol Cairns, CPMSM, CPCS; Hugh Greeley; Todd Sagin, MD, JD; and Sally Pelletier, CPMSM, CPCS. Learn cutting-edge best practices for tackling medical staff challenges and network with colleagues. Here s a sample of what you ll get during the two tracks and general sessions: Track 1: Credentialing & Privileging, Legal & ccreditation Verify & Comply: Understand, Implement, and Comply with Medical Staff Requirements This session offers best practices and an explanation of the biggest pain points in CMS regulations and accreditors medical staff standards compliance. We ll examine similarities and differences in the organizations driven by CMS regulations, including guidance on references for practitioners, and top legal issues. Spotlight on Four Privileging Challenges Who needs to be privileged in what ambulatory settings? Should all telemedicine practitioners be credentialed through the same processes? How can EMTL requirements be managed through privileging? Is there a difference between practitioners with low volume versus no volume? During this session, attendees will learn how to overcome the obstacles around these four privileging challenges. Track 2: Practitioner Performance Managing Disruptive Behavior: ssuring Effectiveness While voiding Legal Landmines This session will address the prevention, detection, and investigation of unprofessional conduct. Explore options for conducting collegial interventions and the landmines that often arise when an organization takes corrective action. By examining difficult case scenarios, attendees will gain an understanding of the litigation that can result from efforts to address difficult practitioner behaviors. Practitioner Performance and Leadership Peer review isn t getting any easier. During this session, the speaker will discuss how the increases in physician employment, conflicts of interest, and data transparency are impacting the peer review process. ttendees will learn best practices in the evaluation of clinical cases and incidents and leave the session armed with the tools to improve their organization s peer review process. General sessions The Effective Credentials Committee Member detailed look at the crucial role of the credentials committee and its responsibilities related to credentialing, privileging, and practitioner performance. This session, with input from all our expert speakers, will help attendees develop the right framework to support the credentials committee from orientation and training for committee members, to policy and procedure development, to strategies to streamline and manage effective credentials committee meetings. Speakers will present the audience with case scenarios and ask that they put themselves in the shoes of the credentials committee to address the challenges presented in the case studies. Focus on OPPE and FPPE ttendees will join the speakers to continue the saga of fictional practitioner Jane dele. This session will focus on Jane s experience with ongoing professional practice evaluation (OPPE) and focused professional practice evaluation (FPPE). By examining Jane s experiences, attendees will learn how to ensure OPPE and FPPE at their organization is relevant, useful, and practical. Using the case study, the speakers will make clear that collecting OPPE and FPPE data is the first step, but the challenge doesn t end there. Organizations must also know what to do with the data once they have it and understand how to deal with identified competency issues. Credentialing and Privileging Rapid Fire In five- to 10-minute segments, our panel of speakers will discuss the top industry concerns, including Federal Tort Claims ct medical malpractice protection, criminal history checks, accreditors then and now, application fees, Internet searches, and the mericans with Disabilities ct. ttendees will gain effective compliance tools and best practice strategies that they can employ the first day back on the job. For the complete agenda or to reserve your CRC Symposium seat, go to www.hcmarketplace.com/the-credentialing-resource-center-symposium. 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400. HCPRO.COM 11

Credentialing Resource Center Journal February 2015 The MSP s voice by Rosemary Dragon, CPMSM, CPCS The upsides of change (yes, there are some!) Change. It s a dirty word to many of us, but as a healthcare worker today, it is inevitable. I doubt there are many of us whose jobs have not been impacted by the changes in our nation s healthcare system. Hospital systems are merging, functions are being centralized, and more is being demanded of us. s we face this change, it can be daunting, removing that sense of control that we all love so much. 2014 was a year characterized by change for me as well, in both my professional and personal life. I had to remind myself many times throughout the year to manage my response to all the changes, and I encourage you to do the same. I have a saying posted above my computer screen: Pessimists usually get what they expect. So do optimists. I continually ponder this statement when things aren t going the way I want them to. The following are some reminders to myself that have come out of these meditations. I hope they help you to manage change as well. Change creates opportunity. To be more accurate, change often forces opportunity. It is easier to allow the status quo to continue rather than pursuing the goals we ve been dreaming about for eons. Hearing rumblings of changes in your department, hospital, or health system may cause you to panic, but it may also be the thing that prods you enough to try for that promotion, study for your CPCS or CPMSM certification, or go back to school. s you work through your initial emotions, consider how this seemingly uncontrollable change could spur you to reach those dreams! Change prevents stagnation. I heard recently about the effect that flowing water has on a lake or pond. If there is a continual flow of water, the body of water is naturally filtered and remains fresh. If the body of water is cut off from that flow, it will stagnate. Even though we often dread change, it keeps our minds fresh, gives us new experiences to reflect on when things are tough, and brings different people and circumstances in our lives to shape us into better people. Change is a cure for boredom. I don t think I ve experienced boredom since my teens, but I attribute that in part to the constant changes of life. Change does not give us either the opportunity or excuse for boredom. If you are bored with your life, job, or circumstances, consider how the change that you may be resisting could address that boredom. Change brings new people into our lives. Most change requires us to interact with people we may have never met or spent much time talking to. Have you ever considered the fact that this change could be the thing that introduces you to your next close friend, your future spouse, or someone who could mentor you professionally? Yes, change sometimes takes those we know and love away from us, but it can also bring vibrant and influential personal and professional relationships into our lives. We need to allow ourselves to embrace the potential blessings in any situation. I know this can seem trite when everything feels like it is falling apart, but it can make all the difference when working through change. For example, at a health system where I previously worked, my department s primary functions were moved out of state. s you can imagine, this was tough to swallow. However, had this not happened, I may not have moved to my current health system, which was one of the best professional decisions I have made. Recall the changes you have faced over the years and try to find the silver lining. If you can identify the beauty amidst the pain of the past, might there be beauty hidden in the changes you are facing today? H EDITOR S NOTE Dragon is medical staff coordinator at St. nthony Hospital/OrthoColorado Hospital in Lakewood. 12 HCPRO.COM 2015 HCPro, a division of BLR. For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at copyright.com or 978-750-8400.