NAMSS News

MS 1 20 Update

In January, The Joint Commission (TJC) announced the establishment of a sixteen-member special fact-finding task force that will examine implementation issues related to revised hospital medical staff standard MS.1.20 and address issues of concern that have been raised by groups such as NAMSS. The task force is composed of 16 individuals including physicians, hospital administrators, and attorneys who represent the diverse viewpoints of the standard. NAMSS is pleased that Dr. Robert Wise, Vice President of the Division of Standards and Survey Methods, invited a NAMSS representative for participation. We are excited that Past President Carol Ostermann, CPCS, CPMSM is representing our views and concerns.

The task force held two meetings in January, including an in-person meeting at TJC headquarters on January 17. Various findings of the task force were presented to the TJC Board of Commissioners on February 29. There continue to be questions surrounding the interpretation of the standard and there is no clarity regarding how the standard will improving patient care.

NAMSS continues to present our concerns that the revised standard may have unintended negative effects on patient care. As you know, many hospitals have moved away from a system of including credentialing and privileging policies and procedural details within the medical staff bylaws. Separating out these policies and procedural details into manuals outside the bylaws ensures that bureaucratic issues do not impair patient care. Changes such as adding privileging requirements for a certain specialty, new procedures, or updates to comply with new safety standards can be modified without having to undergo a lengthy and expensive bylaws amendment process. Mandating this process for these types of modifications could create delay in patients having access to cutting edge treatments. NAMSS presented these patient care concerns to the task force, along with concerns about the potential cost impact of implementing the standard.

Several members of the task force are presenting concerns similar to NAMSS and we are pleased that TJC is listening. Carol Ostermann is working with others to present TJC with additional revisions that will clarify the language of the standard and hopefully be more aligned with the NAMSS position. The task force will continue to work on these changes until consensus can be reached on a revision.

NAMSS recommends that facilities hold off on bylaws revisions resulting from MS.1.20 until the task force issues its final recommendations. This will ensure that any changes you make will be compliant with the final TJC’s interpretation of the standard. NAMSS will work to ensure there is adequate time to prepare for implementation deadline, currently scheduled for July 2009.

NAMSS continues to work as an advocate on behalf of medical staff services professionals to ensure that this standard promotes fair and efficient medical staff governance while improving the safety and delivery of patient care. If you have any questions regarding NAMSS’ position on standard MS.1.20, contact Christine Perez at cperez@namss.org.

Dr. Chassin's Letter

Task Force Final Concerns

CMS is delaying the deployment of the NPI Registry and the dissemination of FOIA-disclosable health care provider data from the National Plan and Provider Enumeration System (NPPES). To read more information click here.

Healthcare Organizations Given a 12 Month Grace Period for NPI Compliance

CMS has announced that it will not penalize any entity not in compliance with NPI guidelines by the May 23, 2007 deadline as long as the entity has a contingency plan and can prove that it is making efforts to fully comply by May 28, 2008.

The National Provider Identifier (NPI) is a 10 digit number that will be used in place of current legacy numbers such as Provider Identification Numbers (PINs), Unique Physician Identification Numbers (UPINs), and National Supplier Clearinghouse (NSC) numbers. The number will be used to link providers to HIPAA transactions such as health care claims and prescriptions. The NPI will not replace taxpayer identifier numbers (TINs) such as Employer Identification Numbers (EINs) and Social Security Numbers (SSNs).

CMS will still enforce the May 23, 2007 deadline for all covered organizations and providers except small health plans to start using the NPI number. However, CMS realized that many entities will not be prepared by next month’s deadline because record-keeping systems such as software and forms must be updated and staff must be properly educated in the new system before a smooth transition can occur. Entities not in full compliance with the NPI system will not be penalized during the 12 month grace period as long as they can provide documentation to CMS proving that they have implemented a contingency plan and are making a “good faith effort” to complete the full transition by May 23, 2008. Organizations are encouraged to end their contingency plans as soon as possible prior to this date but cannot continue them beyond the 2008 deadline.

CMS will be holding a roundtable discussion on the NPI contingency period on Thursday May 10 from 2:00-3:30 PM EDT. It will be of interest to those who are currently working under or developing contingency plans. Callers will have the opportunity to ask questions. To register for the call, click here for more information: http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/NPIRoundTable.pdf.

CMS’ contingency plan guidance document can be found here: http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/NPI_Contingency.pdf