Medical Staff, Telemedicine and Other Changes: Meeting CMS Conditions of Participation and TJC Standards

Recorded Webinar | Laura A. Dixon | From: Nov 30, 2021 - To: Dec 31, 2021

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The Centers for Medicare and Medicaid Services (CMS) hospital CoPs have a section on the medical staff. It includes information on credentialing and privileging requirements, implementing Medical Staff (MS) bylaws and rules and regulations, hospitals in systems.

There are over 2,180 deficiencies from CMS related to the Medical Staff section. Three significant changes became effective November 29, 2019, to the CoPs under the transparency bill, discharge planning, and hospital improvement rule, all of which will be discussed to some extent. This includes changes to the history and physicals for healthy patients having outpatient procedures and changes to the autopsy rules.

CMS allows a hospital system to share a medical staff which CMS refers to as a unified and integrated medical staff.  Additionally, the Medical Staff can credential the dietician to order a diet and the RD can be a member of the medical staff or just C&P without being a member of the Medical Staff. The board and Medical Staff sections will be discussed in detail.

There will also be a concurrent discussion of TJC standards for medical staff. 

Although telemedicine has been a factor in healthcare for many years, COVID-19 gave it a larger role in the diagnosis and treatment of patients. Communicating remotely protects clinicians and patients from the transmission of the SAS-CoV-2 virus. The solution to do this was so obvious that the federal government, some states, and health insurers, quickly suspended regulations that limited telemedicine. It is anticipated that the telemedicine boom will outlive the coronavirus. CMS has made many changes to telemedicine during the COVID-19 pandemic. This will be discussed as well as the 1135 telemedicine waivers.

With all the recent activity in the area of telemedicine are you sure your hospital is compliant with the regulatory standards? Every hospital and critical access hospital that is doing telemedicine should ensure compliance. Both will be discussed along with the new tag numbers for critical access hospitals in 2020 and 2021.

Are you familiar with the federal regulation on telemedicine along with the CMS hospital CoP interpretive guidelines? CMS has been issuing quarterly reports of the number of hospital deficiencies and this program will discuss the most problematic standards in the telemedicine interpretive guidelines. The most problematic standard is the failure of the hospital to have the required sections in the contract for telemedicine services. This webinar will cover what provisions need to be in the telemedicine contract.

The Centers for Medicare and Medicaid Services (CMS) have conditions of participation (CoP) interpretive guidelines for all hospitals regarding their telemedicine standards. These were based on federal regulations. The regulation and interpretive guidelines also impact hospitals accredited by the Joint Commission (TJC). TJC made changes to crosswalk with the final CMS standards, all of which impact both large hospitals, small and rural hospitals, and critical access hospitals.

The regulations cover the credentialing and privileging process for physicians and practitioners providing telemedicine services. This revised process is less burdensome which means it is now a less financial burden for hospitals. CMS allows hospitals to credential by proxy. Hospitals are required to have a written agreement that meets certain criteria. Come learn all about the regulations and interpretive guidelines and the responsibilities of the board, medical staff, and hospitals to ensure compliance with the regulations or ensure you comply.

These standards have the effect of being able to bring the most up-to-date care to the most remote places. Many facilities are investing in equipment to support telemedicine. Make sure your facility complies with the regulations and interpretive guidelines.

Learning Objectives:-

  • Discuss that CMS has a section related to the medical staff
  • Describe that hospitals can have a separate medical staff or a unified shared integrated medical staff
  • Discuss is both a regulation and CMS interpretive guidelines which are now part of the hospital CoPs on telemedicine credentialing and proxy credentialing
  • Recall that CMS will allow the Medical Staff to credential qualified non-physicians to write orders if state law allows
  • Describe the requirements for a medical staff under TJC standards
  • Describe the requirement hospitals have to have a written agreement that specifies the responsibilities of the distant-site hospital and entities to meet the required credentialing requirements
  • Recall that Joint Commission has standards on telemedicine

Detailed Outline:-

  • Policy requirements and no system surveys
  • Three recent laws: autopsies, H&Ps, and infection control
  • Appointment of individuals to the MS
  • MS by-laws and rules and regulations
  • MS accountability for the quality of care
  • Credentialing and privileging frequency
  • Separate medical staff or unified shared integrated medical staff
  • The Medical Staff composition
  • Medical staff duties in credentialing all eligible candidates for medical staff membership and making recommendations to the board.
  • H&P revised rules
  • Care of patients
  • Emergency services
  • Autopsies and changes in 2020
  • TJC Standards for Medical Staff
  • Telemedicine requirements
  • COVID-19 telemedicine and 1135 waivers
  • Federal law and interpretive guidelines by CMS for CoPs
  • CMS deficiencies in telemedicine for hospitals
  • Definitions of distant site telemedicine entity (DTSE)
  • Requirement for and in the written agreement for Telemedicine
  • Telemedicine privileges based on medical staff recommendations
  • Credentialing by proxy
  • Agreements with Medicare-certified hospitals
  • Agreements with DTSE
  • Ensuring compliance with the CoPs
  • Effect on Joint Commission hospitals
  • Basic hospital functions
  • Reliance on the C&P decisions of the distant site
  • Peer review issues
  • Adverse events and notification
  • Periodic appraisals
  • Complaints received about the distant site physician
  • Third-party verification organizations
  • Question and answer session
  • Where CoP tag numbers are changed

Who Should Attend?

  • Chief Medical Officer
  • Medical Staff leader
  • Credentialing and Privileging Professionals
  • Physicians
  • Medical staff office staff and coordinator
  • Teleradiology Professionals
  • Chief Nursing Officer
  • Chief Operating Officer
  • Director of Radiology
  • Director of Pharmacy
  • Hospital legal counsel
  • Risk manager
  • Compliance officer – CMS and/or TJC/DNV
  • Patient safety officer
  • Legal counsel
  • Nurse educator
  • CAH telemedicine standard tag numbers are changing
  • Joint Commission director
  • Accreditation Director
  • Director of Regulatory Affairs
  • Telemedicine director
  • Anyone involved or in contracting for telemedicine services
  • Health information management officer

Laura A. Dixon

Laura Dixon served as the Director, Facility Patient Safety and Risk Management and Operations for COPIC from 2014 to 2020 where she provided safety and risk management consultation and training to facilities, practitioners, and staff in multiple states. Ms. Dixon has more than twenty years of clinical experience in acute care facilities, including critical care, coronary care, peri-operative services, and pain management. She served as the Director, Western Region, Patient Safety and Risk Management for The Doctors Company, Napa, California. Laura holds a Bachelor of Science degree from Regis University, RECEP of Denver, a Doctor of Jurisprudence degree from Drake University College of Law, Des Moines, Iowa, and a Registered Nurse Diploma from Saint Luke’s School Professional Nursing, Cedar Rapids, Iowa. She is licensed to practice law in Colorado and California.