The Office of Inspector General of the Department of Health and Human Services published a notice in the Federal Register seeking comments about physician credentialing practices. The notice asked for public comments in regard to credentialing practices. The OIG posed five specific questions for comment. AMC/NOMA, in response to this notice, developed an Ad Hoc Committee, which prepared and sent a response to the OIG's request for information on economic credentialing. The AMC/NOMA partnered with the Cleveland Academy of Osteopathic Medicine to send a letter to the OIG regarding exclusive/economic credentialing practices in Northeastern Ohio.
The letter provided detailed background regarding the current healthcare landscape in
the greater Cleveland area - i.e. that it is dominated by two major multi-hospital
systems. We voiced our concern that as a result, many of physicians in our area have been,
in effect, forced to "choose sides" between these two mega hospital systems.
While there are physicians in the area who have medical staff privileges at hospitals
owned or controlled by each of the systems, there have been verified instances of what we
view as "economic" or "exclusive" credentialing in our area. The
letter stated that view this type credentialing as a disservice to patients, to
physicians, and to the community. This practice is not consistent with medical ethics, and
is an impediment to quality patient care.
The letter discussed conflict of interest policies as well as the severe impact imposed
upon physicians and our patients by the managed care contracting conducted by the two
hospital systems. Our letter states that the result of this is that in order for
physicians to avoid being denied a significant patient base, and in order for patients to
be able to freely choose physicians, it is necessary for a physician to maintain medical
staff privileges at the hospitals of both systems. However, where one system refuses to
permit the physician to have medical staff privileges at one of its hospitals due to that
physician's relationship with the other system, this deprives the physician of the
opportunity to service a significant patient community, and it deprives those patients of
the ability to receive care from that physician.
Our letter to the OIG included the AMC/NOMA's policy on exclusive/economic credentialing which opposes the use of economic credentialing to determine a physician's qualifications for granting or renewing medical staff membership. The letter also stated that the AMC/NOMA and the CAOM are of the opinion that, based on the anti-kickback law, any arrangement that directly or indirectly ties medical staff privileges to an agreement to refer to and to avoid associations with other hospitals or other hospital systems to or utilize the facilities of one hospital or hospital system raises significant concerns. The concept of conditioning medical staff privileges on a physician's agreement to refer most or all patients to a hospital or hospital system is not in the best interest of patients or the community in which the patients reside. For a complete copy of our letter to the OIG - contact E. R. Biddlestone at the AMC/NOMA offices at (216) 520-1000, ext. 321.
To view the Federal Register and the information concerning physician credentialing go to the following Web site at http://oig.hhs.gov.