FQHC HRSA Site Visit Protocol - Credentialing Process Risk Mitigation

One would think getting providers to review and update their data would be simple, never mind a prerequisite for ongoing employment. However, provider shortages and healthcare worker stress related to COVID has employers (and health centers in particular) wary of compelling providers to do much more than see patients. 

The Council for Affordable Quality Healthcare (CAQH) has been in existence for more than two decades and is most well known in the provider world as a database designed to gather enrollment and credentialing data in a single repository. CAQH ProView is available at no charge and used by more than 1.6 million providers to maintain provider profiles. CAQH sends every four months an attestation to the provider or a designated individual. The objective is to keep information current. Up to date data mitigates delays around initial credentialing for third-party enrollment. And, as discussed below, HRSA/BPHC requires health centers to maintain records of provider data that is up to date.

Recently, a newly signed client forfeited the non-refundable deposit terminated a credentialing/enrollment contract because we require all health center providers to review and attest that the CAQH ProView file is accurate. The medical director, who you think would want/need to lead by example, told the CFO and contract signatory that his CAQH data was aged and erroneous. We were amazed to learn that when asked to update the info, he said he was too busy and flatly refused. Insubordination aside (OK technically peer to peer), how can you have the medical lead refuse to correct information that is inaccurate, thus, knowingly submit false data to third party payers and facilities depending on accurate CAQH data for initial and recurring credentialing and re-enrollment. 

Taken a step further, how can any health center knowingly allow misinformation to exist when the Bureau of Primary Health Care (BPHC) requires affirmation of accurate credentials?

The BPHC’s Health Center Site Visit Protocol (SVP) Credentialing Section, Element C, requires a health center to have “operating procedures for the initial and recurring review (for example, every 2 years) of credentials for all clinical staff members (licensed independent practitioners (LIPs), other licensed or certified practitioners (OLCPs), and other clinical staff providing services on behalf of the health center) who are health center employees, individual contractors, or volunteers.” The language further requires verification of the following:

  • Primary Source Verification (PSV) of Current licensure, registration, or certification 

  • Education and training for initial credentialing, using:

  • Primary sources for Licensed Independent Practitioners (LIP) 

  • Primary or other sources (as determined by the health center) for Other Licensed or Certified Practitioners (OLCP) and any other clinical staff

  • Completion of a query through the National Practitioner Data Bank (NPDB)

  • Government issued ID for initial credentialing using 

  • Drug Enforcement Administration (DEA) registration

  • Current documentation of basic life support training

To be clear, even the smallest health centers struggle to get this work done and comply with HRSA SVP. Even the large health centers struggle if only around the sheer volume of providers and resulting work. Regardless, failing to maintain records and demonstrate compliance puts at risk FQHC status and significant funding. 

Under this Credentialing Element C, evaluators are compelled to interview responsible persons to verify information accuracy and process completeness. Of late, PMG Credentialing clients just have HRSA call our team directly. We maintain records, demonstrate compliance, and HRSA moves along… at least around this topic. 

If Credentialing and Third-party payer enrollment is challenging for your health center, be in touch. Learn more about best practices, technological innovations, and how to assure your health center maintains Credentialing compliance.