Credentialing Waivers and Recommendations During COVID-19

In an attempt to provide pertinent credentialing information regarding CMS 1135 Waivers and NCQA1 recommendations related to COVID 19, this table summarizes how the UUHP Credentialing team proposes to amend current policies to reflect necessary changes that are not just COVID specific, but may also apply to any other type of disaster response. CMS specific response text is in BLUE and NCQA specific response text is in GREEN. Anything in black is policy or procedure related. The relaxation of credentialing standards should only be considered, if in fact organizations are faced with an insufficient number of healthcare professionals to provide needed services to COVID-19 patients.


COVID-19
Practitioners who are hired for COVID 19 disaster response specifically to provide care/submit claims related to a COVID diagnosis do not need to be credentialed.
Any provider hired before 3/1/2020 or those who are due for reappointment during the COVID 19 situation (currently 9/30/2020) should continue to respond to credentialing efforts in order to receive payments for all contracted services.
Delegated partners do not need to credential practitioners who are hired to help with the COVID 19 situation as CMS1135 Waivers are in effect.
All states where UUHP and MHC currently have members has a CMS 1135 waiver in effect and have declared a state of emergency. The FSMB website is also keeping track of state specifics.2
Any Disaster Emergency Response
Providers may administer treatment, during the emergency, to the extent of their license allows, and until such time when the emergent situation no longer exists. If a CMS 1135 waiver is issued, the license need not be active with the state licensing board or verified at the time of appointment. At that point members shall be transitioned back to credentialed providers.
For facilities – any and all required site visits will be postponed or waived. If postponed they will be scheduled at a time when it is safe to complete them.
Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver.
UUHP will confirm waiver status and if/when issued, and practitioner credentialing for those providers/facilities in that state will be waived temporarily.
Other Specifics/Policy Related Items
Add language to policy to reflect credentialing waived criteria due in the event of a disaster requiring emergency response.
Files from 3/1/2020 to 9/30/2020 timeframe will not be pulled in a look back audit for NCQA.
Reappointment (recredentialing) dates shall be extended to 38 months from 36 months for the look back period mentioned above.
Provisional credentialing could be granted from 60 to 180 days for the look back period mentioned above.
UUHP intends to document any derivations to current appointment and reappointment, credentialing efforts using committee minutes and notes within Genie.

1Web site links are from CMS and NCQA guidance in public domain.

2Web site links are from NAMSS COVID 19 training conducted on 4/7/2020 – www.namss.org

From CMS 1135 Waiver Document UUHP/MHC Response UUHP/MHC Additional Response
Medical Staff. CMS is waiving requirements under 42 CFR §482.22(a)(l)-(4) to allow for physicians whose privileges will expire to continue practicing at the hospital and for new physicians to be able to practice before full medical staff/governing body review and approval to address workforce concerns related to COVID-19. CMS is waiving §482.22(a) (1)-(4) regarding details of the credentialing and privileging process. (Please also refer to Practitioner Locations Blanket Waiver listed below.) Provisional credentialing could be granted from 60 to 180 days for the look back period mentioned above. Reappointment dates shall be extended to 38 months from 36 months for the look back period mentioned above.
Physical Environment. CMS is waiving certain requirements under the Medicare conditions of participation at 42 CFR §482.41 and §485.623 to allow for flexibilities during hospital, psychiatric hospital, and CAH surges. CMS will permit non-hospital buildings/space to be used for patient care and quarantine sites, provided that the location is approved by the state (ensuring that safety and comfort for patients and staff are sufficiently addressed) and so long as it is not inconsistent with a state's emergency preparedness or pandemic plan. This allows for increased capacity and promotes appropriate cohorting of COVID-19 patients For facilities – any and all required site visits will be postponed or waived. If postponed they will be scheduled at a time when it is safe to complete them.
Anesthesia Services. CMS ls waiving requirements under 42 CFR §482.S2(a)(S), §48S.639(c) (2), and §416.42 (bl(2) that a certified reeistered nurse anesthetist (CRNA) Is under the supervision of a physician in paragraphs §482.S2(a)(5) and §485.639(c)(2). CRNA supervision will be at the discretion of the hospital and state law. This waiver applies to hospitals, CAHs, and Ambulatory Surgical Centers (ASCs). These waivers will allow CRNAs to function to the fullest extent of their licensure, and may be implemented so long as they are not inconsistent with a state's emergency preparedness or pandemic plan. We do not credential CRNA’s. Providers may administer treatment, during the emergency, to the extent of their license allows, and until such time when the emergent situation no longer exists. If a CMS 1135 waiver is issued, the license need not be active with the state licensing board or verified at the time of appointment.
CAH Personnel Qualifications. CMS is waiving the minimum personnel qualifications for clinical nurse specialists at paragraph 42 CFR §485.604{a)(2), nurse practitioners at paragraph §485.604(b){l}-{3), and physician assistants at paragraph §485.604{c}{l)-(3). Removing these Federal personnel requirements will allow CAHs to employ individuals in these roles who meet state licensure requirements and provide maximum staffing flexibility. These flexibilities should be implemented so long as they are not inconsistent with a state's emergency preparedness or pandemic plan. Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver. Providers may administer treatment, during the emergency, to the extent of their license allows, and until such time when the emergent situation no longer exists. If a CMS 1135 waiver is issued, the license need not be active with the state licensing board or verified at the time of appointment.
CAH Staff Licensure. CMS is deferring to staff licensure, certification, or registration to state law by waiving 42 CFR §485.608{d) regarding the requirement that staff of the CAH be licensed, certified, or registered in accordance with applicable federal, state, and local laws and regulations. This waiver will provide maximum flexibility for CAHs to use all available clinicians. These flexibilities may be implemented so long as they are not inconsistent with a state's emergency preparedness or pandemic plan. Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver. Providers may administer treatment, during the emergency, to the extent of their license allows, and until such time when the emergent situation no longer exists. If a CMS 1135 waiver is issued, the license need not be active with the state licensing board or verified at the time of appointment.
Training and Certification of Nurse Aides. CMS is waiving the requirements at 42 CFR 483.35(d) (with the exception of 42 CFR 483.35(d)(l)(i)), which require that a SNF and NF may not employ anyone for longer than four months unless they met the training and certification requirements under§ 483.3S{d). CMS is waiving these requirements to assist in potential staffing shortages seen with the COVID-19 pandemic. To ensure the health and safety of nursing home residents, CMS is not waiving 42 CFR § 483.3S(d)(l)(i), which requires facilities to not use any individual working as a nurse aide for more than four months, on a full-time basis, unless that individual is competent to provide nursing and nursing related services. We further note that we are not waiving § 483.35{c), which requires facilities to ensure that nurse aides are able to demonstrate competency in skills and techniques necessary to care for residents' needs, as identified through resident assessments, and described in the plan of care. We do not credential nurses’ aides. Providers may administer treatment, during the emergency, to the extent of their license allows, and until such time when the emergent situation no longer exists. If a CMS 1135 waiver is issued, the license need not be active with the state licensing board or verified at the time of appointment.
Special Purpose Renal Dialysis Facilities (SPRDF) Designation Expanded. CMS authorizes the establishment of SPRDFs under 42 CFR §494.120 to address access to care issues due to COVID·19 and the need to mitigate transmission among this vulnerable population. This will not include the normal determination regarding lack of access to care at §494.120(b) as this standard has been met during the period of the national emergency. Approval as a Special Purpose Renal Dialysis Facility related to COVID-19 does not require Federal survey prior to providing services. Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver. Delegated partners do not need to credential practitioners who are hired to help with the COVID 19 situation as CMS1135 Waivers are in effect.
Dialysis Patient Care Technician (PCT) Certification. CMS is modifying the requirement at 42 CFR §494.140{e)(4) for dialysis PCTs t hat requires certification under a state certification program or a national commercially available certification program within 18 months of being hired as a dialysis PCT for newly employed patient care technicians. CMS is aware of the challenges that PCTs are facing with the limited availability and closures of testing sites during the time of this crisis. CMS will allow PCTs to continue working even if they have not achieved certification within 18 months or have not met on time renewals. Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver. Delegated partners do not need to credential practitioners who are hired to help with the COVID 19 situation as CMS1135 Waivers are in effect.
Transferability of Physician Credentialing. CMS is modifying the requirement at 42 CFR §494.180(c)(1) which requires that all medical staff appointments and credentialing are in accordance with state law, including attending physicians, physician assistants, nurse practitioners, and clinical nurse specialists. These waivers will allow physicians that are appropriately credentialed at a certified dialysis facility to function to the fullest extent of their licensure to provide care at designated isolation locations without separate credentialing at that facility, and may be Implemented so long as they are not inconsistent with a state's emergency preparedness or pandemic plan. Organizations do not need to credential practitioners who are part of the organization’s emergency response efforts, if the facility documents their disaster management plan is in effect via website, or notice to plan, or upon issuance of a CMS 1135 Waiver. Delegated partners do not need to credential practitioners who are hired to help with the COVID 19 situation as CMS1135 Waivers are in effect.