As mentioned in a previous post the CMS has instituted new rules regarding provider enrollment requirements for telemedicine applications. Under the previous system, a provider supplying the telemedicine service would need to be credentialed at both medical facilities. This created an unnecessary level of paperwork, time and duplication of effort. The CMS recognized the problem and issues the new rules which allows the receiving hospital to accept the credentials of the telemedicine providing entity. However there are some procedures and caveats that apply.

There are two sets of rules that apply one for hospitals and the other for independent telemedicine entities (ie non-hospital provider organizations that offer telemedicine services). There must be a written agreement between the providing and the receiving medical entity. That agreement must contain certain provisions. For hospitals the lists include the following:

• The physician providing the telemedicine services must be privileged at the originating hospital and that hospital must provide a list of those privileges.
• The hospital providing the telemedicine services must be medicare participating.
• The physician providing the services must be licensed in the state where the patient is receiving the telemedicine services.
• The hospital receiving the telemedicine services must submit a performance review of the telemedicine to the originating hospital.
• The privileging hospital must adhere to the standards set out in 42 C.F.R. §§ 482.12(a)(1)-(7) , 42 C.F.R. §§ 485.616(c)(1)(i)-(vii) and 42 C.F.R. §§ 482.12(a)(8), 482.22(a)(3) and 485.616(c)(2).

With telemedicine entities again both parties must enter into a written agreement that include the following provisions.

• The physician must be privileged at the entity that providing the telemedicine services and that entity must provide a list of those privileges.
• The providing telemedicine entity must comply with all CoP’s related to providing a contracted medical services.
• The credentialing standards of the telemedicine entity must meed the standards set out in 42 C.F.R. §§ 482.12(a)(1)-(7) and 42 C.F.R. §§ 482.22(a)(1)-(2) or 42 C.F.R. §§ 485.616(c)(1)(i)-(vii).
• Again the physician/provider must be licensed in the state where the patient is receiving the service.
• The same internal review procedures as is the case with hospitals.

It important that both parties participating in a telemedicine relationship spent a bit of time up front to insure that the written agreement is in order and that the proper provider enrollment standards are in place.

Many healthcare experts view telemedicine as an important, fast growing trend in medical diagnosis delivery. They believe that widespread use of telemedicine could save the America’s health care system billions of dollars. The projected savings would be realized from a reduction in patient hospitalizations and use of emergency services. But perhaps most importantly, by overcoming distance, time and travel costs, especially in under-served areas, telemedicine would greatly enhance patients access to health care services. It would appear the the CMS agrees with that assessment and has taken a step toward making the credentialing process a bit easier for hospitals employing a telemedicine program.

Currently CMS statues require hospitals to privilege each and every physician who provides telemedicine services to a hospital’s patients as if the physician were actually on-site. Many hospitals, especially the smaller one and those in rural areas are concerned about the paperwork and time burden associated with privileging all the physicians that would be available to them by way of telemedicine resources. CMS has agreed and submitted a revision for comment. (click here for details)

The revision would allow the hospital administration whose patients receive telemedicine services to grant privileges based on recommendations from its medical staff. They in turn would get their information from the hospital where the physician providing the telemedicine was currently privileged. Thereby eliminating the need for a formal credentialing procedure. The new provision does not eliminate the old procedure and a hospital could continue to use the existing process if they so desired.

If a hospital wanted to use the new, proposed option there would be certain procedures that they would have to follow to insure accountability. They would have to verify or perform the following:

• The hospital providing the telemedicine service would have to be a Medicare-participating hospital;
• The telemedicine providing physician is licensed by the state in which the patients receiving the service are located.
• The telemedicine providing physician would have to be privileged at the hospital providing the service.
• The hospital receiving the telemedicine service must perform an internal review of the performance of the providing physician, They would have to send that review to the hospital providing the service to include with their own physician appraisals. That appraisal would have to include any and all problems that arose as a result of the service along with any complaints that were received.

While not totally eliminating all the paperwork and procedural problems that surround telemedicine, it is certainly a step in the right direction. If this proposal goes into effect it should significantly simplify the privileging procedure.