1. What the Term “Provider-Based” Means to the Medical Staff1
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 / v1
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2. Overview of Provider-Based Designation2
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
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4. Provider-Based Designation4
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
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5. I. THE BASICS AS THEY APPLY TO MEDICAL STAFF MATTERS5
I. THE BASICS AS THEY APPLY TO MEDICAL STAFF MATTERS
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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
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8. PB Basics Requirements for Clinical Services8
PB Basics
Requirements for Clinical Services
“Clinical services at the PB department are integrated with the MP”
Reporting relationship
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10. PB Basics Requirements for Clinical Services (continued)
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PB Basics
Requirements for Clinical Services (continued)
Committees’ clinical oversight
Unified record retrieval system
Full access to all services
Referred where appropriate
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11. PB Basics Requirements for Clinical Services (continued)
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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.
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13. PB Basics Requirements for Clinical Services (continued)
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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
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14. PB Basics Requirements for Clinical Services (continued)
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PB Basics
Requirements for Clinical Services (continued)
The MP medical staff committee is responsible for medical activities in the PB
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15. II. WHERE THE PROBLEMS LURK
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II. WHERE THE PROBLEMS LURK
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17. Where are there Problems?
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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?
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18. Where are there Problems?
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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?
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20. Where are there Problems?
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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
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22. III. BEST PRACTICES AND TIPS
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III. BEST PRACTICES AND TIPS
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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
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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
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Compliance Tips

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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
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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
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30. IV. WRAP UP, FINAL THOUGHTS AND QUESTIONS
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IV. WRAP UP, FINAL THOUGHTS AND QUESTIONS
Catherine Ballard, Esq., Executive Director
The Quality Management Consulting Group, Ltd. and Partner, Bricker & Eckler LLP /
© QMCG 2016