Question: We are entering into a contract with a neighboring hospital for teleradiology services. There are going to be about 25 teleradiologists. We want to use the streamlined approach for credentialing and privileging permitted by the Medicare Conditions of Participation. We were just not sure if the teleradiologists still needed to complete our application form and whether we still should require them to sign and return our appointment letter.
Answer: The answers are No and No.
The Conditions of Participation (“CoPs”) allow a streamlined approach for credentialing and privileging physicians who provide telemedicine services. Consistent with the CoPs, as long as your hospital enters into a contract with a distant-site hospital (or distant telemedicine entity) and the contract addresses the regulatory requirements[1], you can rely on the decision of the distant?site hospital in granting telemedicine privileges. You must still have your Medical Executive Committee recommend telemedicine privileges and the Board must act on those recommendations. Additionally, prior to granting privileges, you need to query the National Practitioner Data Bank for each telemedicine physician.
That being said, you are not required to have each telemedicine physician fill out your application form and you are not required to have each telemedicine physician return a signed copy of the appointment letter from the Board. This is an area where you have complete discretion. As with all physicians, if you have a requirement you better follow it. Many appointment letters state that privileges are not effective until the letter is signed and returned. If you let any physician, including a telemedicine physician, practice without returning the letter you are opening yourself up to a claim that the physician was practicing without privileges.
And remember, the streamlined approach for granting telemedicine privileges in the CoPs is just an option. You can always use your standard process for credentialing and privileging. Check your bylaws or credentials policy. Your documents should give you the option to decide what process to follow in granting telemedicine privileges.
[1] The CoPs require that the distant site hospital must participate in Medicare and must provide a current list of the telemedicine physician’s privileges. Additionally, the telemedicine physician must be licensed in the state where the patient is being treated. The local hospital must also review the performance of the telemedicine physician and provide the distant-site hospital with performance information, including information about adverse results and complaints about the telemedicine physician.