Patient Safety and Quality Improvement Act

Credentialing and Privileging Teleradiologists:
The Disagreement Between CMS and the
Joint Commission Persists
Recorded April 3, 2008

Joint Commission standards have made it easier for hospitals and their radiology groups to use the services of teleradiologists. Instead of individually credentialing and privileging each teleradiologist, Joint Commission Standard LD.3.50 allows a hospital to accept the credentialing and privileging decisions of another Joint Commission-accredited ambulatory provider. But the Centers for Medicare & Medicaid Services ("CMS") has taken the position that any practitioner who provides a "medical level of care," including teleradiologists, must be individually evaluated by the medical staff with final action by the Board.

What does that mean for your hospital? Join HortySpringer attorneys Susan Lapenta and Phil Zarone as they review a variety of issues pertaining to the credentialing and privileging of teleradiologists, including:

Joint Commission standards and CMS requirements: How do they differ and what do these differences mean to the contracts you have (or are negotiating)?
Does compliance with Joint Commission standards satisfy the Medicare Conditions of Participation if there is a conflict between the two?
Is there still any need for the hospital to enter into a written agreement with a teleradiology provider when the local radiology group is paying for the teleradiology services?
If the hospital enters into a contract with a teleradiology provider, what issues should it address?
Can the teleradiology group serve as a Credentials Verification Organization (CVO)?
Does the hospital have to maintain a credentials file and a quality file for each teleradiologist?
Should teleradiologists be appointed to the medical staff? Granted telemedicine privileges?
Should they be included in the performance improvement activities of the hospital?
What happens if the hospital is not satisfied with the performance of a teleradiologist? Should quality concerns be handled in accordance with the medical staff bylaws?
If the hospital demands that a teleradiologist be removed from the interpretation panel, is the hospital required to report the teleradiologist to the National Practitioner Data Bank or the State Board? Is the teleradiologist entitled to a hearing and appeal under the bylaws?
What kind of review process must take place for teleradiologists and at what intervals? What information should be considered by the hospital when privileges are renewed?
Are there any payment or billing issues when teleradiologists reside outside of the country?

Audio CD or MP3: $225