Should we pull the providers NPDB reports or request the provider to do a self query?
This has been a common question recently. Therefore, I wanted to relay the information for your review.
According to the information I have researched, in order to pull NPDB reports you must be a "Healthcare Entity". A "Healthcare Entity" is defined as:
Most firms utilize the third definition to determine eligibility as they “provide health care services". But, in order to meet that requirement, there has to be a “formal peer review” process for the purpose of “furthering quality heath care”.
I feel the “providing health care services” and “furthering quality health care” can be argued and possibly in your favor. But, the “formal peer review” process can be a bit problematic. From my understanding and speaking with others, this is understood to be a formal process that is reviewed by an actual physician (or mid-level depending on type of provider). I know of some firms that have went so far as to hire a Medical Director that actually reviews every NPDB so they can bolster their argument in the event an investigation ever occurs. Then again, I am sure others can argue this in the direction where a credentialing expert is a peer and they have a formal process to review them. I can’t really speak to the success of failure of either argument though.
The problem is the penalty is $11,000 per violation and it is retroactive back to every NPDB ever pulled. That being the case, it can be extremely damaging in the event of losing an investigation.
I don’t want to make a mountain out of a mole hill. But, I do want to do everything I can to make sure you are as protected as possible and pass on whatever information or “hot topic” I come across that is concerning. For whatever reason (which there can likely be many), this one has been coming up more and more.