Free CPCS Telemedicine Credentialing and Privileging Standards Questions and Answers — Questions and Answers
Question 1: Under CMS and The Joint Commission standards, when an originating site hospital uses 'credentialing by proxy' for a telemedicine provider, what is a key requirement?
- The telemedicine provider must be a full-time employee of the distant site.
- The originating site must have a written agreement with the distant-site telemedicine entity. (Correct answer)
- The provider must visit the originating site in person at least once per year.
- The originating site must re-verify all of the provider's credentials from primary sources.
Correct answer: The originating site must have a written agreement with the distant-site telemedicine entity.
Credentialing by proxy allows the originating site (where the patient is) to rely on the credentialing done by the distant site (where the practitioner is). A formal written agreement between the two entities is required to outline responsibilities, ensure the distant site is accredited, and meet other regulatory requirements.
Question 2: What is the primary state licensure requirement for a physician providing telemedicine services to a patient?
- The practitioner must be licensed in the state where the distant-site hospital is located.
- The practitioner must hold a license from any U.S. state.
- The practitioner must be licensed in the state where the patient is located. (Correct answer)
- A license is not required if the service is provided through an accredited hospital.
Correct answer: The practitioner must be licensed in the state where the patient is located.
Telemedicine practice is governed by the laws of the state where the patient is physically located at the time of service. Therefore, the practitioner must hold a valid, unrestricted license in that state, regardless of where the practitioner is located.
Question 3: In the context of telemedicine, the 'originating site' is defined as:
- The location of the practitioner providing the service.
- The administrative headquarters of the telemedicine company.
- The location of the patient at the time of the encounter. (Correct answer)
- The billing office for the telemedicine service.
Correct answer: The location of the patient at the time of the encounter.
The originating site is the location of the patient at the time the service is being furnished via a telecommunications system. The distant site is the location of the practitioner providing the service.
Question 4: When an originating site hospital privileges a telemedicine practitioner, what information must its governing body consider?
- Only the practitioner's board certification status.
- The distant site's privileging recommendations and the originating site's performance data. (Correct answer)
- A character reference from the distant site's CEO.
- The number of years the practitioner has been providing telemedicine services.
Correct answer: The distant site's privileging recommendations and the originating site's performance data.
While the originating site can rely on the distant site's credentialing, its own governing body is still responsible for granting privileges. This decision must be based on the distant site's privileging recommendations and any internal performance data specific to the care provided at the originating site.
Question 5: To use the credentialing by proxy process, the originating site must validate that the distant site is a:
- For-profit entity.
- Teaching hospital.
- Medicare-participating hospital. (Correct answer)
- Facility located in the same state.
Correct answer: Medicare-participating hospital.
CMS regulations for credentialing by proxy require the originating site to verify that the distant site is itself a Medicare-participating hospital. The Joint Commission also requires that the distant site be TJC-accredited, if the originating site is using TJC standards for this process.
Question 6: The Joint Commission standards for telemedicine require the originating site to have a process for:
- Ensuring the telemedicine provider uses specific software.
- Reviewing the distant site's financial statements.
- Overseeing performance and managing complaints related to the telemedicine provider. (Correct answer)
- Requiring the provider to carry a minimum of $10 million in malpractice insurance.
Correct answer: Overseeing performance and managing complaints related to the telemedicine provider.
Patient safety and quality oversight are paramount. TJC standards mandate that the originating site must have a defined process to review the performance of its telemedicine providers and to receive and address any patient complaints related to their care.
Question 7: Which CMS Condition of Participation (CoP) was specifically revised to allow for a more streamlined telemedicine credentialing and privileging process?
- Patient Rights (§482.13)
- Medical Staff (§482.22) (Correct answer)
- Quality Assessment and Performance Improvement (§482.21)
- Physical Environment (§482.41)
Correct answer: Medical Staff (§482.22)
The CMS CoP for Medical Staff (42 CFR §482.22) was updated to permit a hospital's governing body to rely on the credentialing and privileging decisions of a distant-site hospital or telemedicine entity, which is the basis for 'credentialing by proxy'.
Free CPCS Telemedicine Credentialing and Privileging Standards Questions and Answers
Under CMS and The Joint Commission standards, when an originating site hospital uses 'credentialing by proxy' for a telemedicine provider, what is a key requirement?