Operational Site Visit - A Credentialing Crisis Averted

A HRSA Operational Site Visit (OSV) is an annual event and to health centers finding themselves ill-prepared, can be daunting if not devastating. Failure to meet requirements can result in corrective action plans, elevated scrutiny, and in extreme cases revocation of health center status and funding.

 While preparation for a visit can be intensive, what to expect is clearly defined by HRSA. PMG Credentialing was approached by a mid-west health center client who found themselves less than short days out from a OSV and knew they’d fail the credentialing portion of the OSV.

 Based on the HRSA Requirements from the OSV Manual Clinical Staffing, Element C: Procedures for Review of Credentials, below are the items an auditor will review:

• Defined procedure for initial & recurring review (e.g., every two years) of Licensed Independent Practitioners (LIPs), other licensed or certified practitioners (OLCPs), & other clinical staff (OCS) providing services on behalf of the health center. REMEMBER to include health center employees, contractors, or volunteers.

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

• Initial Credentialing, Education, and training:

  • Primary sources for LIPs

  • Primary or other sources (as determined by the health center) for OLCPs & OCS

• National Practitioner Data Bank (NPDB) query seeking medical malpractice payments &/or adverse actions

• Clinical staff identity confirmation via current a government-issued, picture ID

• Drug Enforcement Administration (DEA) registration & evidence of current Basic Life Support (BLS) training.

 In addition to telling health centers exactly on what they will be evaluated, the process is expressly detailed under Site Visit Team Methodology:

• Review procedures (including HR procedures, if applicable) for LIPs & OLCPs

• Review procedures for OCS if the health center uses staff who do not require licensure or certification to provide services on behalf of the health center (e.g., non-certified medical/dental assistants, community health representatives, case managers, etc.)

• Review Credentialing Verification Organizations (CVOs) contracts as applicable

• Interview staff who conduct or are responsible for credentialing to determine:

  • Whether education & training for LIPs is confirmed through:

    • PSV obtained by the health center, or state licensing body

      NOTE: If a state licensing body conducts PSV, health center just need document such.

• Documented timeline tracking for recurring review of credentials to ensure currency

 There are other notes about excluding certain items if not relevant and latitude about source verification. However, in general, the guidance is exceptionally detailed and unambiguous. A health center cannot plead ignorance unless the HRSA guidance was literally ignored. Any failure to answer affirmatively that each step is performed and documented will result in the health center providing some sort of written explanation.

 So, based on the above, imagine the urgent phone call received about five months back. At the time, PMG only managed the Licensed Independent Practitioners (LIPs). However, the health center needed PMG to immediately onboard and evaluate all dependent staff; i.e., all OLCPs as well as OCS. The health center, in prep for the review had realized they had never initiated (never mind documented) credentialing of OLCP nor OCS staff. Uh oh.

In eight busy days a focused team of PMG professionals onboarded 64 OLCP/OCS staff about whom no prior record had previously existed. For all 64 staff:

• Credentialing files created & staff onboarded into credentialing software

• Primary & other source verification fulfilled & documented

• Approval letters created, stored, & copies forwarded to client for internal records

 Additionally, as part of credentialing diligence, PMG identified an additional 22 LIPs for whom reappointment was imminent. During this whirlwind of work, these 22 LIPS were able to obtain updated status as new appointment dates were affirmed.

 In short, PMG Credentialing was able to entirely mitigate glaring exposure around HRSA credentialing requirements. Crisis averted. Client happy. Another day (or eight) at the office for PMG’s great team.

 Too often consultants use scare tactics to sell products and services. Don’t be scared but instead, prepared. Contact PMG Credentialing today to learn how our team of experts can manage all your credentialing and third-party payer enrollment needs.