Would Your Governing Board Approve a Medical Staff Appointment Without an Application for Proxy Credentialing?
“Who Is Ultimately Responsible? The CEO, CMO, CMO’s Office, Medical Staff Office, MEC, or Governing Board?”
I never thought I would have to ask this question. Yet here we are.
Imagine being asked to add a clinician to your hospital’s Medical Staff with nothing more than a name and a professional license number.
· No application.
· No NPI.
· No education or training history.
· No work history.
· No professional references.
· No attestation.
· No disclosure statements.
· No evidence of current competence.
Nothing. —- And yet the expectation is that the hospital should simply add the individual to its Medical Staff roster. As someone who has spent decades in Medical Staff Services, credentialing, privileging, and provider governance,
I have to ask:
When did due diligence become optional?
Credentialing has never been about paperwork.
It is about protecting patients.
Every Governing Board, Medical Executive Committee, and Credentials Committee has an independent responsibility to determine whether an applicant meets the qualifications established in the Medical Staff Bylaws before recommending appointment and granting clinical privileges.
That responsibility cannot be delegated simply because another healthcare organization employs the practitioner or has completed its own credentialing process.
The hospital’s duty is to its own patients.
· Its own community.
· Its own Board.
· Its own Medical Staff.
Negligent credentialing is not an abstract legal concept discussed only in courtrooms.
It represents real patients who were harmed because organizations failed to exercise reasonable diligence before allowing a practitioner to provide care.
The question isn’t whether the clinician is qualified.
The question is: How does the hospital know that this Clinician is SAFE for its patients?
Another questions is – these Proxy Organizations that offer services to RHC or any underserved facility, should there be Patient Harm, will these Proxy offering organizations offer to pay for all the legal expenses and pay the patient or take ownership, accountability?
CMS Conditions of Participation (42 CFR §482.22), accreditation standards, and prudent governance – how does this COP get satisfied?
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