ALL ZIPPED UP Maintaining credentialing files appropriately is a time-consuming, detailed process.

If you do your own credentialing, you know it can be a job in itself. Not only is it a challenge to keep up with the regulations and make sure everything is current, but then it's time to re-credential before you know it. But with good preparation and a little creativity, your files can be organized and survey-ready, and contain all the necessary and up-to-date documents. Whether you're the one maintaining your credentialing files or supervising those who do, here are some tips I wish someone would have shared with me.

Prepare a request document for applicants. This document lists everything applicants will need to provide. E-mail it to surgeons and attach facility documents they'll need to complete, including a confidentiality agreement, a Hepatitis B requisition/declination form, and any policies or documents they may need to review. Include a by-laws attestation statement as part of your application process for the potential credentialed staff to sign. It shows that the applicant understands the facility by-laws and agrees to abide by them. Also include a permission slip/waiver for applicant signature so you can run all your checks.

Run your checks. As part of your due diligence, verify all licensure and certifications, both initially and during renewal. Primary source verification has 4 ingredients: a state license check, American Medical Association, National Practitioner Data Bank (NPDB) and Office of Inspector General (OIG). Run all the checks and print verifications. When you enter your applicant into the NPDB, set him up for continuous query so that you're alerted to any changes immediately. This also saves a new query at re-application. Save NPDB e-mails to support your process. An OIG check (exclusions.oig.hhs.gov) ensures there are no Medicare sanctions assigned to your applicant.

Maintain a current photo ID in each file. Replace the copies as they expire.

Check your applicant's insurance. Verify that it meets liability limits and minimums as defined in your facility's by-laws.

Organize your files. How will you set up your files? I like segregating documents by appointment/re-appointment, privileges, licensure and verification, training and education, and health. For confidentiality and convenience should you need to pull those documents, place a removable folder in the health file, which should contain information on TB, flu, hepatitis B, History & Physical, and illness or injury.

Track when documents need to be renewed. Keep a checklist in each file of all documents with a list of their outdates. Maintain each file with tabs in a uniform fashion to keep it organized. Archive the old as the file grows per your facility's record retention policy. Use your Outlook calendar or other tools or apps to remind you when documents need renewal. I've started using the EasilyDo app (easilydo.com) as a reminder tool, and find it helpful.

EMERGENCY PREPAREDNESS
Is Your Facility Disaster-Ready?

IN AN EMERGENCY A new CMS rule insists you show that your facility is prepared for an emergency or a disaster.

Is your facility ready to deal with such natural and man-made disasters as hurricanes, pandemics and terrorist attacks? CMS wants you to prove it. Hospitals, surgery centers and other healthcare facilities have a little more than a year to meet new federal disaster preparedness requirements as a condition of participation in Medicare and Medicaid.

CMS says the goal of its Emergency Preparedness Rule finalized last month is to increase patient safety during emergencies and to establish a more coordinated response to disasters so that a breakdown in patient care similar to what followed Hurricane Katrina and Hurricane Sandy does not recur. The rule requires facilities to develop 4 things:

Visit osmag.net/rvRAC3 for sample plans, tools, templates, and training and exercise materials.

• Emergency plan for disasters specific to your location.
• Policies and procedures based on the plan and risk assessment.
• Communication plan so that patient care is well coordinated in and out of the facility.
• Training and testing program, including initial and annual trainings. You must run emergency drills twice a year, or participate in an actual incident that tests the plan.

"These 4 elements should not be considered overly onerous or intrusive," says Spence Byrum, CEO of HRS Consulting. "They are the very things for which we should be prepared to be able to adequately care for our patients and professionals should the worst happen."

Ambulatory surgical centers will be required to meet most of the same proposed emergency preparedness requirements as those proposed for hospitals, with a few exceptions. ASCs won't have to provide information regarding their occupancy, or provide for subsistence needs of their patients and staff. And only hospitals are required to conduct emergency fuel and generator testing. "But if a facility has an emergency power capability, it would certainly be better to exceed compliance requirements," says Mr. Byrum.

— Dan O'Connor

Don't forget about peer review. When you re-appoint, have your governing body check a statement indicating that it's reviewed peer review activities and considered them as part of the approval process.

Require a new application with each re-credentialing period. If your state doesn't require a standard application, verify that there is an information/liability release statement.

Update your delineation of privileges. Update your delineation of privileges list with any new requested procedures (include CPT codes for easy reference) and get governing board approval as that happens. Once approved, provide a copy to the scheduler so she knows what's appropriate to schedule. Upon re-appointment, create a document for the applicant to sign and request either no changes, or indicate any requested changes with the correlating CPT code. Don't forget to include non-procedure privileges, like moderate sedation and radiology.

Once you grant appointment … provide the applicant with a letter indicating the appointment period, and a reminder that the appointment is based on adherence to the facility's by-laws. Put the re-appointment date in your calendar. OSM