What Policy Information Notices (PINs) and Program Assistance Letters (PALs) should the health center be utilizing as guidance to ensure compliance with Credentialing and Privileging Requirements?
With the release of the Health Resources and Services Administration (HRSA) Compliance Manual (HRSA Compliance Manual), a number of PINs and PALs were eliminated. Included in this list are PIN 2001-16, “Credentialing and Privileging of Health Care Practitioners” and PIN 2002-22, “Clarification of BPHC Credentialing and Privileging Policy Outlined in PIN 2001-16.” As a result, health centers should not utilize these PINs as guidance for compliance. Instead, health centers should follow the guidance outlined in Chapter Five of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5) and the HRSA Credentialing and Privileging File Review Resource (Credentialing and Privileging File Review Resource). Additionally, health centers can conduct a self-evaluation of compliance by answering the questions in the “Clinical Staffing” section of the HRSA Site Visit Protocol (Site Visit Protocol Clinical Staffing). Health centers should utilize PAL 2017-07 (PAL 2017-07) as a resource for granting temporary privileges.
Health centers can conduct a self-evaluation of compliance by answering the questions in the “Clinical Staffing” section of the HRSA Site Visit Protocol (here)
The guidance provided in the HRSA resources above provide the minimum standards for compliance as it relates to credentialing and privileging. Health Centers with Federal Tort Claims Act (FTCA) Deemed status must ensure compliance with FTCA requirements, in accordance with the Federal Tort Claims Act Health Center Policy Manual (FTCA Manual), as they define the highest standards for compliance.
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