QUESTION: We recently received an application from an internist who has moved around a bit more than normal in his nine years of practice (post-training). Though our application form asks applicants to list all institutional affiliations since the completion of training, along with starting and ending dates, we have found that this applicant left out two prior employers and four prior hospitals where he held privileges and, further, have found that four of the starting/ending dates that were listed on the application are off by three to six months.
After asking the applicant about the discrepancy, he corrected the application, said that he could not recall exact months when he started or ended a couple of his affiliations, but was piecing it together the best he could from memory, and said he was sorry that he had not given the application more personal attention the first time around. He further explained that the omission of information from the application was the result of his relying on someone else to fill out the application, in this case, the office manager of the practice that he recently joined. He said that he gave her his CV to use for reference when filling out this application (along with managed care and malpractice insurance enrollment forms), but now realizes that his CV omits a few workplaces where he spent only short periods of time and did not really develop a significant practice. He invited us to call with any additional questions.
He seems cooperative and this all seems like a fairly legitimate explanation. Do we need to do anything else?
ANSWER: The most common explanation for missing or incorrect information on an application form? You got it: “My office manager filled out the form.” In our experience, Medical Staff leaders are often quite forgiving when faced with such explanations. And sometimes, that is reasonable (see above introduction, regarding how even a type-A personality attorney can forget the details about her parent’s anniversary!). But, sometimes, a simple explanation such as this can be a cover for a remarkable history. It is the hospital’s and medical staff leaders’ job to find out which situation you are facing anytime there is an omission or misrepresentation. Good policies can help make the process of following up more methodical and easier to implement.
First, note that some hospitals and medical staffs make it a general practice to simply inform the applicant of a discrepancy in information on the form (versus what has been verified by the Medical Staff office) and then give the individual an opportunity to correct the form! This is generally not a good practice because it basically serves as a “free pass” to any applicant to lie at the outset and then later correct the form, without consequence, if caught in the act.
A better practice is to address all omissions and misrepresentations that are discovered during credentialing in writing addressed to the applicant. Policies should state that misrepresentations and omissions can be grounds for the hospital or leadership to stop processing the application or, if the individual has already been appointed or granted privileges at the time the misrepresentations or omission is discovered, can be grounds for automatic relinquishment upon notice to the practitioner.
Without good policy language, Medical Staff leaders who discover omissions or lies on application forms (or any other information provided during the course of the credentialing process) can be left with little recourse but to deny the application based on the individual’s ethics (or overlook the misrepresentation because they don’t want to deal with a denial and the hearing and appeal rights that it brings). This is too much risk to assume on the part of someone who was not honest and forthcoming about his or her qualifications. Therefore, it’s important that the Bylaws or Credentialing Manual specify how applicants will be informed of omissions and misrepresentations discovered during the course of credentialing, the opportunity they will be provided to explain, how the explanation will be considered, the consequences of any misstatements or omission, and whether any rights to meetings or due process will apply (we generally suggest that they do not).
If you would like more tips for managing applications that include incomplete, incorrect, or unusual information, join us this spring at a Horty Springer seminar covering best practices in credentialing applicants with unusual histories:
Strategies for Managing Physician Health and Disruptive Conduct
The Strategies Seminar provides an engaging opportunity for hospital and Medical Staff leaders to cultivate a sophisticated understanding of the legal and practical complexities that come into play when the most difficult credentialing and peer review issues arise — specifically, those involving practitioner health, disruptive conduct, and conflicts of interest. By working through case studies and complex scenarios, this course will help participants navigate the land mines that can arise when health, conduct, and conflicts are at issue. Experienced faculty will guide participants to develop problem-management strategies that reduce legal risk, help colleagues, and, most importantly, protect patients.
New for the 2018/19 seminar season: Credentialing Dr. Angle. She’s got skills that you’d like to have. But she’s also got an unusual application and it’s just so darned hard to nail down the details. How deep do you really need to dig when, on the surface, the applicant seems so great?
Credentialing for Excellence — Advanced Tools and Techniques
The Credentialing Seminar provides comprehensive training for those involved in all levels of the credentialing process. The seminar is designed for hospital and Medical Staff leaders, Medical Staff professionals, and Board members. Attendees will leave the three-day seminar with the skills and knowledge they need to manage the risks involved in credentialing and to use the credentialing process to establish excellence in the provision of care in their institutions. The seminar is interactive, engaging and thought-provoking so that attendees will get the most out of their experience.