QUESTION:        Our organization’s delineation of privileges (“DOP”) form includes a laundry list of over 200 procedures. We want to move to a core privileging model for each specialty but need some direction on the best way to get started. We are especially concerned about how to address procedures that are done infrequently and/or not specifically listed in the core.

ANSWER:           Many hospitals have moved to “core” privileges and many have struggled with how best to address these types of questions. For a while, many organizations defined their cores somewhat vaguely to be, essentially, anything the physician would have learned in residency training. However, CMS and the Joint Commission let it be known that they did not like this form of core privileging because nobody really knew exactly what the physician was permitted to do. As CMS stated in a 2004 memo, “[s]pecific privileges for each category must clearly and completely list the specific privileges or limitations for that category of practitioner.”

As such, the guidance from CMS and the Joint Commission makes it clear that core privileging cannot be used to avoid the need to identify the specific tasks a physician may perform. Instead, core privileging is a way of grouping privileges based on a determination by the hospital that all the privileges in the group require similar education, training and experience.

What does this mean for those procedures outside of the core? Typically, we see these procedures identified as “special privileges,” meaning that any procedure that falls outside of the core will be included in a list of individual procedures that can only be requested if applicants can show that they have the required additional education, training, and/or experience beyond that required for the core in their specialty.

This means organizations must first decide what is in the core and what special procedures fall outside the core and then develop criteria for both.

This is an example of the types of questions you can ask our lawyers when you attend The Credentialing Clinic, which is being offered in Las Vegas this fall, Naples this winter, and San Antonio in the spring.

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