A member recently asked where to get the best guidance on emergency credentialing and guidelines for providers who will work outside of their regular hospital-defined scope of practice in a national emergency. In our response, we provide general guidance for when and how emergency credentialing is necessary or helpful, as well as links to COVID-19-specific resources related to emergency credentialing.
National emergencies often spark a surge in patient admissions—as seen with the current COVID-19 pandemic—which can quickly deplete medical resources, including the availability of essential staff. Emergency credentialing can support the increased and immediate need for providers, while still ensuring proper credentials and privileges for staff and maintaining regulatory compliance.
When expedited credentialing is needed, the medical staff are responsible for developing criteria for an expedited process, and in these circumstances the governing body may delegate its authority to finalize credentialing and privileging decisions. To be eligible for consideration for expedited credentialing or privileging, an applicant must have submitted a complete application. However, if a medical staff committee previously made a final recommendation that is adverse to the applicant or has limitations, the applicant is ineligible for the expedited process.
In terms of regulatory compliance, Joint Commission's emergency management standards provide that when the hospital activates its emergency operations plan in response to a disaster, and the immediate needs of its patients cannot be met through the usual credentialing process, the hospital may use a modified credentialing and privileging process on a case-by-case basis for eligible volunteer practitioners. The medical staff bylaws must identify the individuals responsible for granting disaster privileges. Facilities must also delineate the type of identification that may be accepted from practitioners as proof of their identity and require that the medical staff office begin the usual credentialing process for temporary privileges as soon as the situation is under control.
On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a number of blanket waivers under section 1135 of the Social Security Act, which is triggered by a declaration of a national emergency. As such, CMS offers the following provider enrollment waivers:
- Waive certain screening requirements.
- Postpone all revalidation actions.
- Allow licensed physicians and other practitioners to bill Medicare for services provided outside of their state of enrollment.
- Expedite any pending or new applications from providers.
- Allow practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location.
- Allow opted-out practitioners to terminate their opt-out status early and enroll in Medicare to provide care to more patients.
CMS has established toll-free hotlines for physicians, nonphysician practitioners, and Part A certified providers and suppliers establishing isolation facilities to enroll and receive temporary Medicare billing privileges.
CMS is also waiving the state licensing requirement—as long as four conditions are met—thereby allowing physicians and nonphysician practitioners to provide services in states they are not licensed in, despite the risks of extending liability protections across state lines. In order to take advantage of the waiver, a provider must meet the following criteria:
- Enrolled in the Medicare program
- Possess a valid license to practice in the state that relates to his or her Medicare enrollment
- Furnishing services—whether in person or via telehealth—in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity
- Not affirmatively excluded from practice in the state or in any other state that is part of the 1135 emergency area
Providers can obtain a 1135-based licensure waiver from CMS by contacting the provider enrollment hotline for the Medicare administrative contractor that services their geographic area.
Hospitals have additional flexibility through modifications to CMS medical staff conditions of participation at 42 CFR § 482.22(a)(1)-(4) that enable hospitals to allow physicians whose privileges will expire to continue practicing at the hospital and to allow new physicians to practice in the hospital before full medical staff/governing body review and approval to address workforce concerns related to COVID-19. Fourth-year medical students who are considering early graduation should review the Accreditation Council for Graduate Medical Education's detailed guidance on early graduation for additional information (also see this follow-up guidance). CMS also notes that state requirements will still apply.
If volunteers are needed, organizations can consult the Emergency System for Advance Registration of Volunteer Health Professionals (ESAR-VHP),a national network of state-based systems that verifies the identity and credentials of health professionals so that they can more readily volunteer in disaster and public health and medical emergencies. Through the program, healthcare facilities can request the help and specific skill sets they need, and state ESAR-VHP programs can then match the best volunteer candidate for the job.
For other circumstances, the following resources can help guide a facility's development of emergency credentialing protocols as a result of COVID-19:
In addition, ECRI updates its COVID-19 Resource Center as information and resources become available.