In this blog, Hugh Greeley addresses primary source verification and the ways that primary sources can be accessed.
For the medical staff services team at a hospital to properly verify a healthcare provider’s credentials for onboarding and granting privileges (at a minimum) a half dozen primary sources would have to be contacted, and those primary source organizations would then verify the respective credential listed on the application.
Examples of primary source institutions that provide verification of credentials:
- Medical schools verify completion of education
- State licensing boards verify license type and status
- An OIG search of the LEIE indicates if the licensee is excluded from participating in government-funded programs
- CMS Medicare and state Medicaid lists of those who have opted-out
- The policy issuer for malpractice insurance
- NPDB for sanctions
- And the list goes on…
It is no wonder that it often takes 90 days or more to onboard and grant privileges to healthcare provider applicants. Bottlenecks can pop up every step along the way. Some examples of typical bottlenecks include:
- The Medical Staff Services Department: This team has a full plate with credentialing new members of its staff, monitoring current staff, and re-credentialing staff among a host of other duties.
- The Primary Source Organizations: Some organizations compile and publish data on a schedule which is typically on a monthly cadence. Delivery of data ranges from a print-out sent by mail, a spreadsheet sent through email, a CSV download from a secure server, or an online searchable database.
- Unpublished Data: In the case where a primary source organization doesn’t publish data, the medical staff services team must contact that organization directly to request verification. There are cases where an institution may have since closed its doors and the paper document needing verification no longer exists.
CVOs to the Rescue
Credentials Verification Organizations, known as CVOs, perform these duties as an in-house department or as a third-party independent service partner. Certifications and accreditations are issued by URAC and NCQA to set and enforce standards and guidelines while ISO 27001 certification assures data security.
Compliance requirements continue to proliferate in order to keep up with the ever-evolving and accelerating fraud schemes as well as meeting high expectations for quality care and outcomes.
CVOs must be equipped to manage big data, assure accuracy of records matching, collect, aggregate, and house the data in a secure environment, and be able to deliver the data securely and in a format that works with the credentialing software or platform used by the healthcare organization.
The following is contributed by Hugh Greeley, author of Hugh’s Credentialing Digest
Let’s talk about the myth and mystique of primary source verification (PSV).
When confirming qualifications, must a hospital or managed care organization contact an applicant’s medical school to confirm graduation, or the dean’s office’s secretary to confirm completion of an approved residency, or the Drug Enforcement Agency (DEA) to confirm a permit, or perhaps the American Board of Surgery (ABS) to confirm board status? Unquestionably, these are the primary sources, yet we know that contacting these entities directly is time consuming, and not always necessary to confirm these credentials.
Hospitals customarily contact either the American Medical Association (AMA) or the American Osteopathic Association (AOA) to obtain such confirmation, or they receive a report from a local or national Credentials Verification Organization (CVO). Presumably, if the CVO is accredited or certified, the hospital has investigated it and designated it as an acceptable source.
Hospitals routinely rely upon the National Practitioner Data Bank (NPDB) for confirmation of licensure actions, sanctions, malpractice payments, and even the presence or absence of disciplinary actions taken by a peer review body (hospital). Yet hospitals have not studied the procedures used by the NPDB and designated it an acceptable equivalent source.
We also know that in a growing number of multi-hospital systems, hospital number one (of five) is able to confirm most credentials and share this knowledge with each of the other hospitals in the system. We do not require that hospital number one be a certified or accredited CVO. Each hospital knows the process used to obtain confirmation and has designated it as an accepted source per policy.
Why then can’t a hospital in, let’s say, Massachusetts designate the state medical board as an acceptable equivalent source, after some investigation of its processes, and rely upon the information stored in its extensive licensure file for credentialing purposes?
Under current accreditation standards, a hospital could designate just about any entity as its CVO, provided that its research and investigation into the policies and processes satisfy its concern for accuracy, security, liability, and other salient issues. One does not need to ask that worn-out question, “Has the Joint Commission approved it?” The Joint Commission’s standards already give accredited organizations ample latitude to determine what mechanism they will use to validate practitioners’ credentials. Admittedly, the organization will need to be able to demonstrate to the surveyor or auditor that relevant credentials have been verified through an approved source (equivalent to the actual primary source).
As hospitals and other organizations charged with the job of verifying both qualification and competence recognize the easy availability of nearly all necessary information obtainable from either primary or approved equivalent sources or data consolidators known as CVOs, the often arduous task of tracking down this information one primary source at a time will give way to data technology, the power of digital data collection, aggregation, analytics, and secure data delivery methods.
The day is fast approaching when a hospital will be able to verify qualification and current competence with a quick download from a single approved source, bolstered by an NPDB report.
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|Written by Hugh Greeley
Credentialing and Healthcare Industry Expert
HG Healthcare Consultant