May 17, 2012

Question: A registrant at our recent Complete Course for Medical Staff Leaders asked: “Should an AHP be on the Credentials Committee?”

Answer: CMS has for years required that non-physician practitioners who provide a “medical level of care” be credentialed and privileged as required by CMS.  (These include Advanced Practice Nurses such as Nurse Midwives, CRNAs and Nurse Practitioners and Physician Assistants.  However, not everyone realizes that CMS expects RNFAs to be privileged through the Medical Staff process.  See The Interpretive Guidelines in the Medicare State Operations Manual Condition of Participation: Surgical Services.)  Now, the newly revised Medicare Conditions of Participation (CoPs) published within the last week explicitly encourage hospitals to appoint non-physicians to the Medical Staff and to serve in expanded roles, in accordance with state laws.

Some Credentials Committees already have a subcommittee to deal with privileging for non-physician professionals.  One or more APRNs and PAs can be included as members of a Credentials Committee or a subcommittee or they can be invited when needed.  Their input can be valuable for development of eligibility criteria for privileging.  (Note that nomenclature is evolving; APRNs and PAs may prefer not to be lumped into a category called “AHPs.”  Some organizations refer to these individuals collectively as mid-level providers, Advanced Practice Clinicians or Advanced Practice Professionals.)

What will these provisions of the new CoPs mean for your hospital and Medical Staff?  What’s required and what’s up to each organization?  Join HSM for an audio conference on June 28 as part of our 4-part series on practical implications of the new CoPs.