Credentialing & Privileging

#NAMSS23 Recap: APPs Privileging and Training: All That Is Hidden Will Be Made Clear

By Regina Plank, CPMSM

I had the privilege of speaking at the NAMSS 47th Educational Conference on one of my favorite, yet most challenging, topics: advanced practice providers privileging and training.   

Although the concept of advanced practice provider (APP) “training up” within the healthcare setting, i.e., hospital, is not a new concept, it is still a struggle to gain acceptance and support of full disclosure, acknowledgement, and a structured process with oversight. 

I am fortunate to have gained that support and have embarked on the journey of moving forward with a training in progress (TIP) process at my current facility. 

Below I will share some tips that I have learned along the way.

Warning signs that APPs are training at your facility without oversight include:

• Issues identified from compliance/billing; billing without privileges.
• APPs requesting new privileges — where are the case logs from? Your facility?
• APP leaders requesting that privileges be added to the privilege forms.
• In review of APP protocols and standardized procedures/delegation agreements, etc., procedures/privileges are on their documents, but they do not currently have the privilege and have not requested the privilege.
• Newly graduated APP applying, joining a specialty, group, or supervising physician.
• APPs transferring to a new department/specialty.

Potential consequences of not having a concrete APP training process with oversight and guardrails:

• APP practicing/performing procedures without privileges.
• Compliance/regulatory issues.
• Bypassing processes (may be due to APPs not understanding or fully being educated on “privileges” and what that means related to their scope of practice at your facility) which may be different from the supervising physician agreement(s) they have in place. Do they know that they need to request a change in privileges? Do they know about FPPE processes, etc.?
• Inappropriate billing.
• When transferring from one specialty area to another, do they have the appropriate malpractice insurance coverage, supervising physician, or collaborative agreements?  Do their privileges need to be revised? Do they need training, or are they competent to perform the new privileges? 

Tips and questions to consider when beginning the journey of developing a training in progress process:

• Find a physician champion.
• Select an appropriate clinical department to use as a beta site.
• Develop a good rapport with APP leadership. They will be your experts.
• Get the process approved by your medical staff (leverage).
• Consider what your request for a new privileges process looks like, as it will have impact on the flow. Also, keep in mind FPPE after training and approval of privileges.
• Create a streamlined approach to make the flow and timeline from start to finish as easy and seamless as possible.
• Consider notifying other departments that may be affected: HIM, finance, billing.

Areas to focus on when drafting your training in progress process:

• The workflow: assure that it is very specific and defined from the start (includes notification to MSPs that training is beginning before training begins, flow to modification of privileges [after training is completed], and FPPE requirements.
• Identification of a preceptor. Assure that a preceptor is identified and acknowledges (in writing) their responsibilities and role as a preceptor. Note: Preceptor is not a proctor.
• Applicant acknowledgement. Assure that the applicant acknowledges (in writing) the requirements of the training process.
• Specific forms for documentation of training during the entire process.
• Once the flow has been created, obtain approval by your medical staff leadership, i.e., medical executive committee.
• After approval, provide education throughout your facility as appropriate, i.e., chiefs/chairs, APP leaders, and supervising physicians. Consider rolling out education for one clinical area/department at a time.

Lastly, I encourage you to review all your APP privilege forms. Do they need to be updated? If so, begin that journey and concurrently consider incorporating the training in process provisions for specific privileges into your APP privilege forms.

Keep strong MSPs, and remain diligent as we continue to be advocates for our patients!