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The Joint Commission Announces Revisions in Response to CMS Final Rule

Wed, 05/27/2020 - 22:37
The Joint Commission recently announced standards changes in response to the Centers for Medicare & Medicaid Services (CMS) final rules on Burden and Discharge Planning. The first set of changespertains to the hospital deeming renewal application with CMS, effective July 1, 2020. The second set of changesapplies to both hospitals and critical access hospitals, effective September 13, 2020.

Prepublication standards:Visit the Joint Commission Standards Page additional information on these updates. Stay connected to NAMSS by visiting the NAMSS COVID-19 Resources Page.

Medicare Clarifies Recognition of Interstate License Compacts

Wed, 05/20/2020 - 22:36
On May 5, CMS recognized several new interstate license compacts for physicians and non-physician practitioners. The uptick of telehealth services due to COVID-19 has increased the urgency for these compacts.

CMS will require practitioners under a compact to fulfill both the licensure requirements in their primary state and the requirements outlined by the interstate compact laws that each state participating in the compact adopts. The interstate license compacts will be handled as credible licenses that meet CMS federal license requirements.
Medicare Administrative Compacts (MACs) will now accept CMS-855 enrollment applications from practitioners with an interstate license compact and allow previously denied applications to be reconsidered for processing. The following resources are available for additional information:View the full CMS article here for additional information. Stay connected by visiting NAMSS COVID-19 Response Page.

Joint Commission Statement on Mental Health Care for Providers and Healthcare Staff

Wed, 05/20/2020 - 22:33
On May 12, the Joint Commission released a statementon the importance removing the barriers to mental health treatment for healthcare providers and non-clinical staff. The COVID-19 pandemic places additional pressures on healthcare workers, but many do not seek mental health support or treatment because they believe that it could negatively affect their careers, credentials, or licensing statuses.

The Joint Commission strongly encourages organizations not to inquire about a practitioner’s history of mental health and supports the FSMB's and AMA's recommendation, “to limit inquiries to conditions that currentlyimpair the clinician’s ability to perform their job.”
The Joint Commission supports eliminating any obstacles and policies that discourage healthcare workers from obtaining mental health services. It is critical that organizations pay attention to healthcare workers’ mental health and ensure they have access to mental health treatment during this time.
Visit the Joint Commissions Coronavirus Resource Page for more resources on staff health and wellbeing. Stay connected to NAMSS by visiting the NAMSS COVID-19 Resources Page.

CMS Expands Emergency Declaration Blanket Waivers for Health Care Providers

Fri, 05/15/2020 - 21:39
On May 11, the Centers for Medicare & Medicaid Services (CMS) expanded telehealth services and relaxed certain requirements with the issuance of additional waivers. The recent waivers and further expansion of telehealth services add to those CMS released at the end of March will remain in place through the end of the COVID-emergency declaration. Among other areas, the waivers:
  • Expand the types of healthcare practitioners who may be reimbursed for Medicare telehealth services to all practitioners who are eligible to bill Medicare for non-telehealth services. 
  • Permit more services via audio-only technology. CMS no longer requires two-way, real-time interactive communication between patient and practitioner for certain services. Please review the CMS list of Medicare telehealth services.
  • Allow physicians to continue practicing at the hospital where their privileges would otherwise expire and for new physicians to practice prior to full review and approval by the credentialing body.
  • Waive the minimum personnel qualifications for clinical nurse specialists and physician assistants.
  • Defer staff licensure, certification, or registration to state law.
  • Enable long-term care facilities to take 10 working days to provide a resident a copy of their requested records.
Visit CMS Coronavirus Waivers & Flexibilities Page for additional information. Stay connected by visiting NAMSS COVID-19 Response Page.

CMS Releases COVID-19 Interim Final Rule and Updates Flexibilities

Fri, 05/08/2020 - 20:18
The Centers for Medicare & Medicaid Services (CMS) recently issued an Interim Final Rule detailing all COVID-19-related waivers and flexibilities for hospitals, practitioners, service providers, and other CMS programs.  CMS provides facts sheets on its Waivers and Flexibilities Resources Page as well as a full list of emergency declaration blanket waivers for healthcare providers. CMS is accepting comments on its Interim Final Rule for 60 days from its May 8, 2020 official publication in the Federal Register.

Stay connected by visiting NAMSS COVID-19 Response Page.

NAMSS and ATA Host Webinar: Telemedicine Legal Considerations: Credentialing by Proxy

Wed, 05/06/2020 - 18:55
On April 23, NAMSS teamed up with the American Telehealth Association to host a webinar “Telemedicine Legal Considerations: Credentialing by Proxy.” The webinar covered the legal and practical aspects of credentialing by proxy, telemedicine lessons learned from the COVID-19 crisis, and the NAMSS-ATA Credentialing by Proxy (CBP) Guide.

Webinar presenters described telemedicine’s rising status amid COVID-19 because it enhances care for those in COVID-19 hotspots, remote locations, provides quality and timely specialty care in areas without specialized practitioners, improves care continuity and case management, and enables patients to receive care without sacrificing quality over convenience.
Diane Meldi, MBA, CPCS, CPMSM, NAMSS Government Relations Liaison, Ty Bozkurt, MBA, FACHE, ATA Board Member, and Maureen Kozlowski, CPCS, CPMSM presented the NAMSS-ATA Credentialing By Proxy- A Guidebook, a resource medical staffs can use to modify credentialing and privileging requirements to facilitate telehealth services.  The webinar highlighted the challenges the traditional credentialing process imposes on telemedicine, especially for tertiary facilities or specialty groups who deploy multiple practitioners to provide services, many of whom are providing services in multiple facilities and perhaps in multiple states. The webinar provided guidance on how healthcare facilities could use proxy credentialing to address these barriers.
CBP is an alternative credentialing mechanism medical staffs can use to obtain telemedicine services for their patients and credential telemedicine practitioners who deliver their services from distant-site entities. Originating-site entities can use CBP to streamline the credentialing process to efficiently expand service offerings and clinical support, without burdening medical staff personnel. For distant site entities, CBP reduces the paperwork, time, and expenses associated with credentialing practitioners at the originating sites.
The “Telemedicine Legal Considerations: Credentialing by Proxy” webinar speakers:
  • Alan Einhorn, JD, Foley & Lardner, LLP
  • Ann Mond Johnson, CEO - American Telehealth Association
  • Diane Meldi, MBA, CPCS, CPMSM, Senior Consultant - Ministry Medical Staff Mercy Quality & Safety Center, NAMSS Government Relations Liaison
  • Maureen Kozlowski, CPCS, CPMSM, Director - Support Services Mercy Virtual
  • Ty Bozkurt, MBA, FACHE, Chief Technology Officer - Burn and Reconstructive Centers of America, ATA Board Member
The “Telemedicine Legal Considerations: Credentialing by Proxy” webinar recording will be available for purchase on the NAMSS website this Friday, May 8. In the meantime, stay connected by visiting NAMSS COVID-19 Response Page.

CMS Recommendations on Non-Emergent Non-COVID-19 Health Services

Wed, 04/29/2020 - 01:01
The Centers for Medicare & Medicaid Services (CMS) issued updated guidance to healthcare providers “on providing essential non-COVID-19 care to patients without symptoms of COVID-19 in regions with low and stable incidence of COVID-19.”  This guidance is a part of Phase 1 of the Trump Administration’s Guidelines for Opening Up America Again.

CMS recognizes the need to be flexible and to allow facilities in regions with low and stable COVID-19 incidences to provide non-emergent, non-COVID-19 healthcare to patients who need this care. When states or regions meet Opening Up America’s Gating Criteria for COVID-19 symptoms, cases, and hospital capacity they can begin to enter Phase I of the Administration’s Plan.

CMS encourages providers and patients to use virtual-care services, such as telehealth when appropriate, to limit COVID-19 exposure.

Stay connected by visiting NAMSS COVID-19 Response Page.

Guidelines for Reopening the Government

Wed, 04/29/2020 - 00:59
In mid-April, President Donald Trump recently released Guidelines for Opening Up America Again. The initiative provides gating criteria that states and regions can use to determine the appropriate time for states to begin taking steps to reopening businesses, schools, and public spaces. The plan enables state governors to decide when their states and regions within their states should begin reopening. Each phase of the Administration’s reopening plan includes guidelines for states, individuals, and employers.

The Opening Up America Gating Criteria requires states to meet the following milestones before beginning the phased re-opening process:

  • A downward trajectory in flu-like and COVID-like syndromic cases for 14 days;
  • A downward trajectory in COVID-19 cases over a 14-day period; and
  • Hospital capacity to provide crisis care and implement/activate

Stay connected by visiting NAMSS COVID-19 Response Page.

HHS Launches Telehealth Resource Site

Fri, 04/24/2020 - 20:17
HHS has launched a Telehealth site to provide guidance to patients and providers during the COVID-19 Public Health Emergency. The HHS Telehealth site’s patient page includes telehealth definitions, policies, and tips on navigating telehealth options. The provider page includes recommendations on integrating telehealth into practice, updates on COVID-19-related policy changes, and assistance on shifting processes to accommodate telehealth appointments.

Stay connected by visiting NAMSS COVID-19 Response Page.

HHS Workforce Toolkit and Preparedness Gateway for Stakeholders

Fri, 04/24/2020 - 19:54
This week, the Health and Human Services Assistant Secretary of Preparedness and Response (ASPR) launched a COVID-19 Workforce Virtual Toolkit to help state and local healthcare decision makers expand workforce flexibilities during the COVID-19 pandemic. The Toolkitprovides guidance for states on funding flexibilities, liability protections, workforce training, best practices, and peer-to-peer communication. It also helps states administer these flexibilities to increase frontline medical staff and care for patients at local hospitals, clinics, and other healthcare facilities. This effort is part of the ASPR Technical Resources, Assistance Center, and Information Exchange (TRACIE), a healthcare emergency preparedness information gateway that provides information and resources for stakeholders through participation in a public-private information sharing exchange that requires registration and approval. 
Stay connected by visiting NAMSS COVID-19 Response Page.

HRSA Temporarily Waives NPDB Query Fees

Thu, 04/16/2020 - 19:52
Effective immediately, HRSA will waive National Provider Data Bank (NPDB) query fees through May 31, 2020 to help facilities respond to, and prepare for, the COVID-19 emergency.  HRSA will host two teleconferences to provide more information about the fee waiver on Thursday, April 16 and Thursday, April 23, 2020—both at 1pm EDT. 

This fee waiver is retroactive from March 1, 2020. HRSA will issue query credits to entities that have paid querying fees between March 1, 2020 and April 15, 2020. The Federal Register will post this official notice on Friday, April 17, 2020.
For more information about NPDB fee waivers, visit HRSA’s NPDB page.  Stay up to date on NAMSS’ COVID-19 Response.

ECFMG/FAIMER Provide a Critical Role in Verifying IMGs

Wed, 04/15/2020 - 20:55
As states continue to waive certain licensure requirements and licensure renewal requirements to respond to the COVID-19 emergency, efforts to provide streamlined and appropriate verification are critical. To help verify international medical school certifications and has passed components of the U.S. Medical Licensing Examination, the Education Commission for Foreign Medical Graduates (ECFMG) is working to provide verification information on international physicians to states as quickly as possible.

ECFMG and its non-profit arm, the Foundation for Advancement of International Medical Education and Research (FAIMER), stands by as a resource for providing state medical licensing personnel information on IMG. Upon request, ECFMG will verify an IMG’s certification, provide basic identity verification and primary-source verification for a physician’s medical education credentials. The ECFMG/FAIMER can also verify provide previously verified credentials, as well as verify new credentials such as medical diplomas, transcripts, medical licenses, and registration certificates.
Contact ECFMG/FAIMER (casemanager@ecfmg.org) for verification assistance, USMLE exams, IMG credentials, and other inquires related to IMGs. ECFMG does not issue physician licenses and does not have information on physician eligibility for credentialing and/or privileging.
Learn more about ECFMG/FAIMER’s COVID-19 Resources.Stay up to date on state licensure waivers from FSMB.Stay connected by visiting NAMSS COVID-19 Response Page.

The Joint Commission Provides a Follow-Up FAQ to its Homemade Face Masks Statement

Fri, 04/10/2020 - 22:46
On April 6, The Joint Commission posted an FAQin response to their statementon homemade PPE. The FAQ provides background and additional protocol for the Joint Commission’s position on healthcare workers using homemade PPE and on hospitals prioritizing N95 masks and N95 respirators for high-risk staff exposed to aerosolized viral particles.

The FAQ also provides additional prioritization guidance to help hospitals conserve N95 masks and other PPE for high-risk personnel.  
Visit the NAMSS COVID-19 Page for more MSP resources.

Healthcare Groups Call Upon Federal Government to Address PPE and Medical Equipment Shortages

Thu, 04/09/2020 - 19:09
In late March, the Joint Commission, American College of Physicians, American Hospital Association, American College of Surgeons, American Medical Association, and the American Dental Association called upon the federal government to drastically increase PPE and other medical equipment production and distribution. In a public statement these groups state their concern with PPE, ventilators, swab kits, shortages, as well as overall testing capacity for COVID-19. These organizations represent frontline caregivers, institutions, and personnel who are at greater risks for COVID-19 exposure   and need more critical PPE immediately. The lack of PPE poses an additional risk to patients and caregivers compounded by the lack ventilators and other life-saving medical equipment, places healthcare facilities at a dangerous disadvantage against COVID-19. Efforts to increase PPE and medical-equipment production and distribution, as well as expands telehealth services are critical to preserving PPE and stopping the COVID-19 spread.  

Joint Commission Issues Statement on Homemade Personal Protective Equipment

Tue, 04/07/2020 - 23:19
On March 31, the Joint Commission released a statementsupporting policies that permit healthcare workers to bring their own facemasks or respirators to work if their healthcare facilities cannot provide enough PPE to protect them from COVID-19 risks. The Joint Commission statement recognizes that:
  1. Hospitals must conserve PPEs during shortages for workers who perform high-risk procedures.
  2. Privately owned PPE’s full ability to protect hospital workers from COVID-19 is unknown, but may provide some degree of protection.
  3. The Joint Commission does not have standards or regulations prohibiting hospital staff from using homemade PPE. 
  4. Hospital workers should only use homemade masks when standard PPE is unavailable.
Read more about the evidencethe Joint Commission used to develop this position.

CMS Provides Hospitals Flexibilities to Support COVID-19 Efforts

Fri, 04/03/2020 - 22:52
The Centers for Medicare and Medicaid Services (CMS) recently issued a series of waivers and modifications to help prepare and equip healthcare systems and workers to meet patient-demand resulting from COVID-19. These efforts seek equip hospitals for COVID-19 surges, expedites healthcare practitioner onboarding, and expands telehealth services, increases site-based COVID-19 testing, and reduces paperwork requirements.

These issuances will remain in effect throughout the COVID-19 Public Health Emergency. The following may affect your medical staffs: 
    •  CMS Hospital without Walls (Temporary Expansion Sites)o   Conditions of Participation Modifications §  Enables ambulatory surgery centers to provide hospital services to help meet patient volume. §  Grants freestanding emergency departments a pathway for treating patients during the declared emergency. o   Paperwork Reduction§  Waives certain paperwork requirements for hospitals facing significant strain from COVID-19. §  See CMS guidance for the specific waived requirements. o   Physical Environment§  Allows designated health systems to use offsite, non-hospital buildings such as hotels and community facilities for patient care, room and board, and other patient services. §  Enables facilities to separate non-COVID-19 patients to reduce exposure.o   Temporary Expansion Sites §  Waives certain COP requirements to allow provider-based departments to establish and operate as a hospital.§  Enables hospitals to change their provider-based department location status to meet patient needs in a specific area.o   Critical Access Hospital Length-of-Stay§  Waives the 25 CAH-bed requirement. §  Lifts the 96-hour length-of-stay requirement. o   CAH Status and Location§  Lifts the CAH rural-area stipulation to help meet patient surge.§  Removes location parameters so CAHs can help with surge capacity.o   Hospital Acute-Care Patients in Excluded Distinct Part Units§  Allows acute-care facilities to house acute-care patients in excluded distinct-part units, as appropriate.§  Provides documentation guidance via the applicable patients’ medical records.o   Telemedicine §  Modifies hospital and CAH telemedicine conditions to expand telehealth services. §  Enables patients to receive telehealth care through agreements with off-site hospitals. Patients over Paperwork    •  Verbal Orderso   Grants facilities flexibility for verbal orders. o   Maintains read-back verification requirements but extends the authentication requirement to 48 hours.     •  Reporting Requirementso   Extends the time period hospitals have to report intensive-care patient deaths who required soft-wrist restraints.o   Increases the reporting period to close of the next business day.     •  Limit Discharge Planning for Hospital and CAHso   Waives certain requirements regarding discharge planning and care goals.o   Facilities should work with patients, families, or patient representatives to select post-acute care providers by using and sharing data with post-acute entities.     •  Emergency Preparedness Policies and Procedureso   Waives requirements to establish emergency preparedness communication policies.o   Lifts requirements to provide contact information for staff, entities providing services under arrangement, practitioners, and volunteers.     •  Provider Enrollmento   Makes available toll-free hotlines for providers.o   Waives certain screening requirements, postpones all revalidation actions, and expedites pending or new provider applications. Workforce    •  Medical Staff Requirementso   Waives COPs to allow physicians with expiring privileges to continue practicing at their current facilities. o   Enables new physicians to start practicing in a hospital before medical staff or governing body approval to help meet patient surges.     •  Physician Serviceso   Lifts requirements that Medicare patients be under a physician’s care.o   Enables physician’s assistants and nurses to help meet patient surges.     •  Anesthesia Serviceso   Lifts current nurse anesthetist supervision requirements and permits facilities to set temporary supervision parameters, in accordance with applicable state law.o   Allows nurse anesthetists to function at the fullest extent of their licenses, as it complies with facilities’ activated emergency plans.    •  Respiratory Care Serviceso   Waives requirement that facilities designate in writing qualified personnel to perform specific respiratory-care procedures and their appropriate supervision levels.o   Requires state and activated emergency plan alignment.     •  CAH Personnel Qualificationso   Waives federal minimum personnel qualifications for clinical nurse specialists, nurse practitioners, and physician assistants.o   The above practitioners must still meet state-licensure requirements and scope parameters.     •  CAH Staff Licensureo   Defers all staff licensure, certification, or registration to state law by waiving COP requirements that staff be licensed, certified, or registered in compliance with federal, state, and local laws. o   Defers all licensure, certification, and registration requirements for CAH staff to the state. 
The CMS COVID-19 site provides more information on the above modifications, as well as other facility modifications. 
Additional CMS Guidance:    •  The Interim Final Rule and Waivers     •  Provider Guidance for Relaxed Quality Reporting Programs     •  Standards of Practice Flexibility Guidance for Hospital Facilities     •  EMTALA Flexibility Guidance 

HHS Secretary Calls for Governors to Ease Onboarding Protocol as Part of COVID-19 Response

Tue, 03/31/2020 - 20:24
U.S. Health and Human Services Secretary, Alex Azar, recently requestedthat governors modify their states’ onboarding protocol to enable more practitioners to meet the current and upcoming patient demand related to COVID-19.

The Secretary’s letterasks governors to take the following eight actions:
  1. Relax state-licensure requirements and enable practitioners with out-of-state licenses to provide services in person and remotely.
  2. Waive certain regulatory requirements so practitioners can more readily establish patients, diagnose, and delivery treatment options via telemedicine services.
  3. Ease scope-of-practice parameters so more practitioners can provide services in all applicable care settings.
  4. Enable physicians to supervise more practitioners, remotely and via telephone.
  5. Expedite certification and licensure processes for certain practitioners.
  6. Compile state liability protections for in-state and out-of-state practitioners, paid and volunteer. Modify or temporarily withdraw medical malpractice policies that do not cover practitioners that facilities onboard in response to the COVID-19 emergency.
  7. Enable medical students to triage, diagnose, and treat patients with supervision from a licensed medical staff member.
  8. Amend laws or regulations that require signatures for pharmaceutical deliveries.
The Secretary also asks governors to invoke existing state-compact agreements that enable states to modify normal protocol to expand healthcare services and increase access to healthcare practitioners. Look for more information and guidance from the HHS COVID-19 Page.
Visit the NAMSS COVID-19 Page for more MSP resources.

Guidance on the Joint Commission’s Temporary and Disaster Privileging Policies

Mon, 03/30/2020 - 20:07
As COVID-19 increases the demand for healthcare personnel, hospitals are activating their emergency plans to quickly onboard practitioners to meet patient demand. In the current national emergency, the Secretary of Health and Human Services has modified certain CMS requirements, including Conditions of Participation, by invoking 1135 Waivers. This enables hospitals to amend their credentialing and onboarding processes to quickly accommodate more practitioners. The Joint Commission provides the following guidance on temporary and disaster privileging for such emergencies through Medical Staff Chapter, Standard MS.06.01.13.

Temporary Privileges
Per Medical Staff Chapter, Standard MS.06.01.13, Joint Commission-accredited hospitals may grant temporary privileges to quickly increase its number of privileged practitioners when the current number of privileged personnel cannot meet patient volume.

Disaster Privileges
The Joint Commission refers to Emergency Management Chapter, Standard EM.02.02.13 protocol to enable its accredited hospitals to provide temporary privileges once their governing body or hospital board activates their emergency operations plans and need to increase privileged personnel to meet patient demand.  According to Standard EM.02.02.13, EP2 refers to the hospital’s medical staff bylaws to identify the personnel responsible for issuing disaster privileges. In designated emergencies, accredited hospitals may also privilege volunteer licensed independent practitioners.

Typically, those who are licensed independent practitioners in professions that a hospital medical staff recognizes and privileges can practice without supervision. MSPs should refer to their hospital bylaws and state licensure laws to confirm supervision requirements.  State licensure law will also provide guidance on practitioner supervision requirements.

Through Standard EM.02.02.15, the Joint Commission also enables its accredited hospitals to privilege volunteer practitioners who are not licensed independent practitioners, but required to have a license, certification, or registration.

Credentialing and Privileging for Temporary Privileges
The Joint Commission requires its accredited hospitals to verify a practitioner’s current license and competence, as well as document the current need for granting temporary privileges via the MSO Chief of Staff or designee recommendation, in the practitioner’s credentialing file.  MSPs should also query the NPDB before granting temporary privileges.

All hospitals that provide temporary or disaster-related privileges must have protocol for overseeing these practitioners. The Joint Commission provides more logistical guidance on credentialing practitioners during disasters, as well as overseeing practitioners with temporary or disaster-related privileges.

Additional COVID-19 Hospital Resources:
The Joint Commission’s COVID-19 Page.
NAMSS
American Hospital Association
Arent Fox

Member Telemedicine Credentialing Resource: NAMSS-ATA Credentialing by Proxy Guidebook

Sat, 03/28/2020 - 00:00

The sudden reliance on telemedicine amid the COVID-19 pandemic prompts many questions on credentialing practitioners for services not originally considered for telemedicine. The resulting questions often fall to MSPs, who are essential to ensuring and streamlining practitioner access during this pandemic. As such, NAMSS would like to remind its members that the NAMSS/ATA (American Telemedicine Association) Credentialing by Proxy Guidebook is available for this very purpose.
In August 2019, NAMSS introduced the NAMSS-ATA CBP Guidebook, which provides guidance on proxy credentialing for practitioners providing telemedicine. The Guidebook is a result of a multi-year collaborative effort between NAMSS and ATA members that originated from the need to develop a process to more efficiently facilitate proxy credentialing—and to establish standards and guidance for the CBP process. 
The CBP Guidebook also includes an overview of credentialing practitioners providing telemedicine, laws and regulations around telemedicine credentialing, a set of guidelines institutions can use to create CBP programs, and potential solutions to obstacles institutions may encounter when with implementing or facilitating a CBP process. The CBP Guidebook is also applicable for implementing modified credentialing and privileging requirements for additional medical professionals to respond in emergencies such as pandemics.
NAMSS is monitoring the evolving COVID-19 pandemic and is committed to serving you and the medical service profession. Useful resources and information can be viewed here

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