On July 5, 2011, The Centers for Medicare and Medicaid Services regulation revising the conditions of participation(CoPs) for both hospitals and critical access hospitals (CAHs) for the credentialing of telemedicine physicians becomes effective. Prior to this date, a hospital or CAH receiving telemedicine services had to go through a burdensome credentialing and privileging process for each physician and practitioner providing telemedicine services to its patients. The new law removes this undue hardship and financial burden.
The prior regulations required a hospital’s governing body to appoint all practitioners to its hospital medical staff and to grant privileges using the recommendations of its medical staff. In turn, the hospital medical staff used a credentialing and privileging process, provided for in CMS regulations, to make its recommendations. CMS requirements do not take into account those practitioners providing only telemedicine services to patients. Consequently, hospitals applied the credentialing and privileging requirements as if all practitioners were onsite. This traditional and limited approach failed to embrace new methods and technologies for service delivery that might improve patient access to high quality care.
CMS came to the conclusion that this previous requirement was a duplicative and burdensome process for physicians, practitioners, and the hospitals involved in this process, particularly small hospitals and CAHs, which often lack adequate resources to fully carry out the traditional credentialing and privileging process for all of the physicians and practitioners that may be available to provide telemedicine services. In addition to the costs involved, small hospitals and CAHs often do not have in-house medical staff with the clinical expertise to adequately evaluate and privilege the wide range of specialty physicians that larger hospitals can provide through telemedicine services.
Essentially, the new provisions will allow for the governing body of the hospital (or the CAH’s governing body or responsible individual) to rely upon the credentialing and privileging decisions made by the distant-site telemedicine entity when making its own decisions on privileges for the individual distant-site physicians and practitioners providing such services, if the hospital’s governing body (or the CAH’s governing body or responsible individual) ensures, through its written agreement with the distant-site telemedicine entity, that the distant-site telemedicine entity’s medical staff credentialing and privileging processes and standards meet or exceed CMS standards.
The removal of unnecessary barriers to the use of telemedicine may enable patients to receive medically necessary interventions in a timelier manner. It may enhance patient follow-up in the management of chronic disease conditions. These revisions will provide more flexibility to small hospitals and CAHs in rural areas and regions with a limited supply of primary care and specialized providers. In certain instances, telemedicine may be a cost-effective alternative to traditional service delivery approaches and, most importantly, may improve patient outcomes and satisfaction.
