Onboarding the Community, Contracted, and Employed Physicians Session Code: WE05 Time: 8:30 a.m. 10:00 a.m. Total CE Credits: 1.5 Presenter: Christine Mobley, CPMSM, CPCS
On-Boarding the Employed, Contracted, Community Practitioners and Recruitment Connection Christine Cris Mobley, CPMSM, CPCS President, C Mobley & Associates, LLC Co-Founder/Owner, Edge-U-Cate, LLC Colorado Springs, CO (719) 587-2871 cris@edge-u-cate.com 2 OBJECTIVES Define the similarities and differences among employed, contracted and community providers in the credentialing process. Identify sources that influence the on boarding process Describe the connection between recruitment and credentialing making it work. 3 1
In the Old Days We credentialed physicians and dentists. Period! Their received delineated privileges, albeit it loosely defined. They had their own practices in the community and came to the hospital to see patients or to perform procedures on them in the hospital. 4 Times Have Changed! Employed Providers Contracted Providers Independent Community Based Providers Providers include physicians, dentists, clinical psychologists, NPs, PAs, podiatrists, registered dieticians, nurse anesthetists and many more. The settings include hospitals, managed care-health plans, ASCs, large medical practices, medical homes, ACOs, LTC, etc. All go through an onboarding process. 5 Defining Provider Onboarding Provider onboarding is the comprehensive system by which newly privileged practitioners are fully integrated into your healthcare organization, its culture and the local community. A good onboarding program will help create a warm, welcoming, and inviting start for the new practitioner to your organization and sets the stage for retention. 6 2
Onboarding Matrix - I Federal HCQIA CMS NPDB Medical-Medicaid Rehab Act 1973 ADA DEA FMLA Telemedicine Shared Savings (ACO) 1964 Civil Rights Act Fraud & Abuse Stark State FMLA State Laws HR-Employment Laws Anti-Discrimination Laws HCO Licensure Laws Boards (MD, DO, Nursing, Podiatry, etc.) Telemedicine Scope of Practice Regulations 7 Onboarding Matrix - II Accreditation Standards Contracts Medical Staff TJC DNV HFAP AAAHC CIHQ Others Employment Agency Personnel Academic Affiliation Exclusive The Bylaws MS Rules & Regs MS P&Ps Credentialing Manual Privileges Manual 8 Onboarding Challenges Which laws and regulations control the situation? What happens when there are multiple accreditation standards? 9 3
Onboarding Providers Alignment between employment requirements Contractor agreements Medical Staff Bylaws Credentialing Process 10 The Role of the MSP Alignment leader Facilitator Team player in credentialing process change Ask the right questions Identify credentialing process risks Make practical suggestions Craft practical solutions Emphasize timely communication 11 ACOs Shared Savings Program An ACO whose screening reveals a history of program integrity issues and/or affiliations with individuals or entities (including ACO participants and ACO providers/suppliers) that have a history of program integrity issues may be subject to rejection of their Shared Savings Program applications or the imposition of additional safeguards or assurances against program integrity risks. Federal Register 76(212): 67955 November 2, 2011. 12 4
ACO Notice? No mention is made of the word Credentialing in the regulation. Focus on integrity not clinical. 13 Credentialing in the World of the Rehab Act of 1973, the ADA, the EEOC and More 14 The Applicable Laws in Context The laws set minimum standards of care Designed to safeguard rights of individuals Balance with patient safety 15 5
Case Example - I Dr. Jettingham checked yes on his application to the following question: Have you ever been convicted of a criminal offense? If you answered yes please provide an explanation of the criminal offense and when it took place. At age 22 I was convicted of possession of an illicit drug. I served 300 hours of community service. I have not use recreational drugs since that time. 16 Case Example - II Thad Ross, NP, checked off on his application that he had been convicted of a criminal offense. He explained: It was about 5 years ago. I was working with a troubled adolescents at a camp. An event occurred involving one youth and I plead guilty to a Class 1 Assault, a misdemeanor. I paid a $250.00 fine. 17 Case Example - III Dr. Haggarty practiced general surgery for 40 years. He retired from surgical practice five years ago. He is applying for employment as a hospitalist. Dr. Haggarty is 73 years of age. He has never taken any boards in internal medicine. You or one of your colleagues did the initial screen of the application packet and sighed, Something is funny about this one. 18 6
Onboarding Credentialing Analysis - I Each application merits individual review. Rules and process should be consistent. Are there any differences between Case I and Case II? What would you do in each instance? Why? What about Case 3? How would you handle the application? When in doubt ask for assistance 19 Onboarding Credentialing Analysis - II State law protections are like an umbrella. If you go beyond the confines of the protection of the umbrella of state laws, you will be rained upon with requests for protection and access to what was previously protected information. KEY WORDS & PHRASES Abrogation Voluntary relinquishment of evidentiary protection Discoverability Admissibility So what is protected in credentialing? BE CAREFUL! 20 The Connection Between Recruitment and Credentialing 21 7
Physician Recruitment on the Rise Physicians seeking employment more security less hassle better income better hours Increase in medical services Patient population growing baby-boomers requiring more healthcare More satellite facilities = more staff More hospital-owned practices 22 Recruitment can be more difficult Shortage of newly trained specialists Location attraction Retention the grass is greener. Physician choices slanted towards personal motivators, lifestyle, work hours -- 4 Goals of Successful Recruitment 1. Qualified Candidate meets criteria for all anticipated practice locations / plans 2. No surprises in credentialing process 3. Everyone involved knows when the new practitioner is scheduled to begin work (and timeline is reasonable) 4. All credentialing/privileging is completed prior to practitioner s start date 2 4 8
Why combine / partner? OBJECTIVES : Identify value in coordinating recruitment and credentialing Recognize strategies to facilitate good communication between recruitment and credentialing Define partnering processes to achieve successful recruitment and credentialing 25 The Recruiter A modern day version of Yenta the Matchmaker. Remember what Yenta said: Oy! Do I have a match for you! 26 Recruiter & Credentialing The Role of the Recruiter Identify good candidates for credentialing in the HCO. (May do phone interviews, background) Do initial rule out of less than ideal candidates Set expectation of the process. No competency judgment Credentialing Complete the credentialing and privileging process as delineated by the Medical Staff and Board app d. Review information from recruiter. Look for consistencies in recruiting data sent to credentialing as part of the packet 27 9
How do you spell o-o-p-s? Recruitment and credentialing are often the most damaging communication miss-connects, costing the recruiting organization and the candidate time, money and embarrassment 28 Practical Issues Information does not match between recruiter packet and application for appointment to the medical staff. Recruiting team wants data from the Credentialing Office that would make their screening process more efficient and effective; i.e., the NPDB report EEEEEKK! Recruitment signs contract and physician sells home and moves family before credentialing is completed!! Recruiters may not be familiar with the credentialing and privileging process. What should take place to address the situation? 29 Does this sound familiar? Hospital just recruited new ED physician and he starts work Friday MSP just informed, and CEO wants temp privileges processed. What can MSP do to avoid this scenario? Find out who is responsible for recruiting in your organization Establish a dialog and educate the recruiter about credentialing processes and timelines Offer your assistance 30 10
Does this sound familiar? A group practice just hired a new surgeon, but the first the Medical Staff Office heard about it was when name appeared on call schedule! What can MSP do to avoid this scenario? Communicate with local group practices a reminder that credentialing takes time Offer to meet with recruiter to offer information on credentialing requirements Ask them to notify you when recruitment is in process, or candidate selected be proactive! 31 Does this sound familiar? Group practice just recruited a physician, but he doesn t meet privileging criteria at one or more hospitals or managed care plans Did the group practice know what the various criteria for privileges were? Or who to ask? Did the group practice share criteria with the recruiter? Or did the recruiter know to ask? Did the recruiter share that criteria with the applicant? Or ask about special procedure interests? 32 Example: RECRUITMENT REQUIREMENTS: General Surgeon Criteria Your XYZ OP Surgi- Surgi- BCBS Aetna Cigna Hospt Hospt Clinic Ctr A Ctr B ACGME/AOA Residency -completed X X X ABMS Board General X X X X X Surgery (Current)* Required to maintain Board Cert X X 12 mo active practice during prev 24 mo.** X X X Specific CME X X requirements Unrestricted License X X X X X Specific privilege criteria X X X X 33 11
PARTNERING! 4 Goals of Successful Recruitment AND Credentialing! 1. Everyone involved knows when a recruitment is initiated / anticipated start date of new recruit Identified players/established communication 2. Qualified Candidate meets criteria for all anticipated practice locations/mc plans Identified position mission affiliations/criteria 3. No surprises in credentialing process Identified red flags during recruitment 4. All credentialing/privileging is completed prior to practitioner s start date Shared Information for timely credentialing; reasonable start date 34 Overall Conclusion - I Use good onboarding processes. Address alignment issues with HR and others to foster good credentialing processes. Case-by-case analysis. Set expectations for you and your department. Use a team approach to address program alignment issues impacting employed, contracted, or independent community based providers NO SILOS 35 Overall Conclusion - II Get legal advice from knowledgeable counsel when setting up or revising the credentialing process. Speak UP! Ask questions and get clear answers. Remember: you are the leader in this area. 36 12
Overall Conclusion III COMMUNICATION COMMUNICATION COMMUNICATION QUESTIONS? 38 Christine S. Cris Mobley, CPMSM, CPCS President, C Mobley & Associates, LLC (CM&A) Co-Founder and Manager, Edge-U-Cate, LC 2345 Academy Place, Suite 109 Colorado Springs, CO 80909 (719) 597-2871 PH, (719) 325-7034 Fax www.cmobley.com; mobleycs@aol.com Christine Cris Mobley, CPMSM, CPCS, is President of C Mobley & Associates, LLC located in Colorado Springs, CO. Her company, established in the early 90s following 14 years employment in several health care systems, provides consulting, risk assessment, and education/training services to hospitals, health systems, CVOs and others primarily in the areas of credentialing, privileging, peer review, medical staff governance and CVO start-ups. Ms. Mobley is also a Co-Founder and Manager of Edge-U-Cate, LLC, a national educational company offering week-long Credentialing Schools for beginners and those more experienced as well as certification focused study live webinar series. She is a published author for Aspen Publishers, HCPro and NAMSS, and, a frequent speaker at state and national programs, sharing her many years experience in this profession, as well as providing expert witness services. She is a NAMSS instructor, former NAMSS President and regional rep, former CVO surveyor for NCQA (1996-2013), and Colorado Association Past President. 2015 13