What the Term “Provider-Based” Means to the Medical Staff 1 ALASKA ASSOCIATION OF MEDICAL STAFF PROFESSIONALS June 16, 2016 What the Term “Provider-Based” Means to the Medical Staff Catherine Ballard, Esq., Executive Director The Quality Management Consulting Group, Ltd. and Partner, Bricker & Eckler LLP cballard@qmcg.com/cballard@bricker.com 614.227.4848/614.227.8806 10093426v1 © QMCG 2016

Overview of Provider-Based Designation 2 Overview of Provider-Based Designation I. The Basics as they Apply to Medical Staff Matters II. Where the Problems Lurk III. Best Practices and Tips IV. Final Thoughts © QMCG 2016 1

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Provider-Based Designation 4 Provider-Based Designation You have decided to convert certain locations to a provider-based status. This means that you have: Done everything that we are going to talk about from a credentialing/privileging/medical staff perspective. Definitions: PB: Provider-Based MP: Main Provider MS: Medical Staff © QMCG 2016 2

I. THE BASICS AS THEY APPLY TO MEDICAL STAFF MATTERS 5 I. THE BASICS AS THEY APPLY TO MEDICAL STAFF MATTERS © QMCG 2016 3

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7 PB Basics PB Designation Requirement Criteria for ALL (On- or Off-Campus) Facilities/Organizations Licensure Clinical Services Integration (today’s focus) Financial Integration Public Awareness © QMCG 2016 4

PB Basics Requirements for Clinical Services 8 PB Basics Requirements for Clinical Services “Clinical services at the PB department are integrated with the MP” Reporting relationship © QMCG 2016 5

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PB Basics Requirements for Clinical Services (continued) 1010 PB Basics Requirements for Clinical Services (continued) Committees’ clinical oversight Unified record retrieval system Full access to all services Referred where appropriate © QMCG 2016 6

PB Basics Requirements for Clinical Services (continued) 1111 PB Basics Requirements for Clinical Services (continued) The professional staff at the PB location must have clinical privileges at the Main Provider. The MP maintains the same monitoring and oversight of the PB as it does for any other department of the medical staff. © QMCG 2016 7

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PB Basics Requirements for Clinical Services (continued) 1313 PB Basics Requirements for Clinical Services (continued) The PB medical director is under the same type of supervision and accountability as any other director, medical or otherwise, of the MP. The medical director at the PB maintains a reporting relationship with the chief medical officer or similar official of the MP © QMCG 2016 8

PB Basics Requirements for Clinical Services (continued) 1414 PB Basics Requirements for Clinical Services (continued) The MP medical staff committee is responsible for medical activities in the PB © QMCG 2016 9

II. WHERE THE PROBLEMS LURK 1515 II. WHERE THE PROBLEMS LURK © QMCG 2016 10

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Where are there Problems? 1717 Where are there Problems? Requirement: Professional staff members at PB facility have clinical privileges at the MP Is maintenance of privileges at PB contingent upon maintenance of privileges at MP? © QMCG 2016 11

Where are there Problems? 1818 Where are there Problems? Requirement: Same monitoring and oversight How will you conduct FPPE? OPPE? Is there a service line or other type of professional services agreement in place? © QMCG 2016 12

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Where are there Problems? 2020 Where are there Problems? EMTALA A provider-based location is a department of the Hospital Whether it will be qualified as a ‘dedicated emergency department’ will depend upon the nature of the service (office practice as compared to urgent care center) Even if it is not, the PB still has obligations © QMCG 2016 13

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III. BEST PRACTICES AND TIPS 2222 III. BEST PRACTICES AND TIPS © QMCG 2016 14

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2424 Best Practices Best Practices to Comply With PB Clinical Services Integration Walk through the requirements from both PB and MP perspectives Determine what invasive procedures are to be done at MP, at the PB location and/or both Take your current department and medical staff processes at the MP and customize to the PB location Policy or description of program scope with PB in appropriate committee, e.g., quality committee © QMCG 2016 15

2525 Best Practices Cont. Policy, schematic and detail on quality and utilization oversight of PB by the MP; and responsibilities of PB back to MP Position descriptions of PB medical director and MP chief medical officer that cross reference PB/MP duties/responsibilities and reporting requirements Policy or description of steps on how record retrieval/pulls/IT access between the PB and MP will be accomplished © QMCG 2016 16

2626 Compliance Tips

2727 Compliance Tips Drill patient record retrieval between MP and PB locations Create a schematic of PB employees by position, title, description, authority, reporting Do not duplicate credentials files on privileged practitioners with proof of privileges at PB – use access to MP files © QMCG 2016 17

2828 Compliance Tips Cont. PB policies should have incorporated descriptions of monitoring/oversight of facility (committees/director) by MP Description of the relationship and clinical care oversight (QA/PI/UR/Peer) activities by the MP chief medical officer/MEC with the PB medical director at MP and PB Establish PB patient record ID, EMR, IT in concert with MP © QMCG 2016 18

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IV. WRAP UP, FINAL THOUGHTS AND QUESTIONS 3030 IV. WRAP UP, FINAL THOUGHTS AND QUESTIONS Catherine Ballard, Esq., Executive Director The Quality Management Consulting Group, Ltd. and Partner, Bricker & Eckler LLP cballard@qmcg.com/ cballard@bricker.com 614.227.4848/614.227.8806 © QMCG 2016