Social Security Death Master File and LEIE Monitoring

Medical Provider Resources recognizes the need to meet federal and state regulations as they pertain to basic credentialing and monitoring functions. The Social Security Death Master File is a computer database file made available by the United States Social Security Administration since 1980. The file contains information about persons who had Social Security numbers and whose deaths were reported to the Social Security administration from 1962 to the present, or persons who died before 1962, but whose Social Security accounts were still active in 1962. MPR is registered with the Limited Access Death Master File (LASMF) as an entity with a genuine fraud prevention interest.

The final rule published in the Federal Register on June 1, 2016 describes how institutions and others may become certified to received data from the LADMF. Per the CMS Medical Program Integrity Toolkit to Address Frequent Findings 42 CFR 455.436, “The Social Security Administration’s Death Master File (SSADMF) must be searched at the time of enrollment to ensure that Medicaid is not being billed in the name of a deceased provider.” Disclosure of search results outside of the MPR service agreement is strictly prohibited under 15 CFR 1110.200. Furthermore, according to the CMS Medical Program Integrity Toolkit to Address Frequent Findings for federal database checks (42 CFR 455.436), “In addition to conducting their own ongoing exclusion searches, states should instruct all enrolled Medicaid providers to check their own employees and contractors for exclusions against the LEIE – List of Excluded Individuals and Entities- at the time of hiring and on a monthly basis.”

In response to the federal regulations, the Social Security Death Master File at the time of initial appointment, in addition, MPR will query the LEIE monthly on behalf of any provider covered under a MPR Centralize Verification Service (CVS) agreement. The findings of the LEIE monthly query will be provided to each participating entity in the On-going Monitoring Service (OMS) report.

Sources:
Medicaid Program Integrity – Toolkits to Address Frequent Findings: 42 CFR 455.436
State Medicaid Director Letter #09-001, dated Jan. 16, 2009
42 CFR 1003.102 Basic for civil money penalties and assessments
42 CFR 1002.3 Disclosure by providers and State Medicaid agencies
NTIS Final Rule on Limited Access Death Master File

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Telemedicine Credentialing and Privileging

If anyone were to ask me what the future of credentialing looks like, I would have to say it can be summed up in one word…collaboration. Without collaboration, the credentialing industry will be unable to move forward. As much as I enjoy seeing health care facilities working together, it’s especially rewarding to see different licensing and accreditation organizations working together.

The Centers for Medicare and Medicaid Services (CMS) and The Joint Commission (TJC) have established standards that permit a hospital to rely on the credentialing and privileging decisions of the entity where the physician is based.  This collaboration helps hospitals conserve resources and make needed specialties available to patients.  To fully comprehend this collaboration effort we must first understand the terms:

1)      Distant Site:  Physical location of a practitioner/provider who is remotely seeing a patient or consulting with another provider via telemedicine/teleradiology.

2)      Originating Site:  The physical location of a patient and/or the patient’s physician/provider during a telemedicine encounter or consult.

3)      Telemedicine:  The use of electronic communication tools to transmit medical information between distant sites.

4)      Telemedicine Entity:  Under CMS regulations, a Telemedicine Entity is one that:  (a) provides telemedicine services;  (b) is not a Medicare-participating hospital; and (c) provides contracted services to a hospital in a manner that enables the hospital to meet applicable Medical Conditions of Participation (CoPs).  For example, an organization that provides teleradiology services may be a Telemedicine Entity.

Collaboration in Action

The CMS regulations permit hospitals to grant privileges to telemedicine practitioners based on the credentialing and privileging decisions of a Distant Site hospital or a Telemedicine Entity.  This is great news for smaller hospitals overwhelmed by the burden of privileging specialty physicians.  In order for the hospital to take advantage of the alternative process permitted by CME, there must be a written agreement with the Distant Site or Telemedicine Entity.  The agreement must speak to:  (a) credentialing and privileging (The Distant Site hospital must be a Medicare-participating hospital and thus governed by the CoPs related to credentialing and privileging. The Telemedicine Entity must adhere to the CoP requirements for credentialing and privileging as well); (b) list of privileges (The Distant Site – where the practitioner is physically located- must provide the Originating Site – where the patient is physically located – a list of the practitioner’s privileges.); (c) licensing (the telemedicine practitioner at the Distant Site where the provider is located or Telemedicine Entity must hold a license to practice in the state where the patient is located; (d) information exchange – the Originating Site where the patient is located must review the provider’s performance of those services and send to the Distant Site where the practitioner is located performance information for use in the periodic appraisal of the provider.

Important Note

The board of directors of the Originating Site is where the patient is located, but grants clinical privileges to telemedicine practitioners.  What we know about granting privileges is that a Data Bank query is required.  The Data Bank query must be performed on behalf of the Originating Site where the patient is located.

Also of importance to note is the different requirements for a Joint Commission accredited hospital.  If your facility is Joint Commission accredited, the Distant Site or Telemedicine Entity whose credentialing and privileging decisions are being relied upon must be accredited by the Joint Commission as well.

Conclusion

Hospitals that wish to provide telemedicine services are not required to rely on the credentialing privileging decision of Distant Site hospitals or Telemedicine Entities.  Some hospitals may prefer to fully credential and privilege telemedicine practitioner using their standard medical staff process.   But, it is nice to know that the opportunity to collaborate with a Distant Site exists in easing the burden of credentialing and privileging.

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Changes in Board Certification – Maintenance of Certification

The old adage “nothing ever stays the same” holds true for us in the field of medicine. One might argue more so than any other chosen professional field.  Maintenance of Certification (MOC) is not a new term to those in the field of medical staff services.  The introduction dates back to the year 2000 when the 24 Member Board of ABMS agreed to evolve their re-certification programs to one of continuous professional developmentABMS Maintenance of Certification ® (ABMS MOC®).

Rather than sitting for board exams following completion of residency and re-certifying within a specified window for the specific specialty, the ABMS MOC assures that the physician is committed to lifelong learning and competency in a specialty and/or sub-specialty. ABMS MOC requires ongoing measurement of six core competencies. Medical Staff Professionals (MSPs) will recognize these from the Joint Commission Standards.

The Six Core Competencies

Maintenance Based on Six Core Competencies

Measurement of these competencies happens in a variety of ways, some of which vary according to the specialty. This is carried out by all Member Boards using a four-part process that is designed to keep certification continuous. In 2006, all Member Boards received approval of their ABMS MOC program plans. The boards are now in the process of implementation.

Part I: Licensure and Professional Standing
Part II: Lifelong Learning and Self-Assessment
Part III: Cognitive Expertise
Part IV: Practice Performance Assessment

Although we’ve been introduced to this idea since the beginning of 2000, the challenges still remain on two fronts:  1) the provider and 2) the medical staff services professional (MSPs).  The specific challenge for MSPs is in tracking on-going certification.

In a recent conversation with Michael Coyne, ABMS Product Management and Business Development (mcoyne@abms.org), MPR learned certain boards recommend verifying their diplomats on an annual basis on or near mid-February of each calendar year.

In an effort to keep accurate records on all provider board certifications, MPR will use CertiFacts for primary source verification of all ABMS Board Certification and perform the following:

1)    For providers with a lifetime board certification with no “end” date, we will use February 15th as the expiration to check the board certification (via CertiFacts) for renewals.

2)    For providers with a Maintenance of Certification (MOC) we will use the re-verification date as the expiration to check the board certification for renewals.

3)    For providers with a time limited certification, we will use the expiration date listed on the board certification verification.

This approach should assure we are routinely aware of all board certification expirations and afford us the opportunity to meet our client needs in supplying the most current document for the credential file.

If you would like to read more about the Maintenance of Certification (MOC) process, please contact the American Board of Medical Specialties (ABMS) at http://www.abms.org/maintenance_of_certification/ or contact ABMS Solutions at (800) 722-2267.

 

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