OIG Recommends States to Include Staff Credentialing Compliance On LTC Surveys in 2024

The Office of Inspector General (OIG) has rekindled its interest in the staff credentialing processes within Long Term Care (LTC) organizations, emphasizing the need for a meticulous approach to ensure the highest quality of care delivery. 

Arguably, the most valuable asset of LTC organizations is their employees. Without qualified employees and health aides, LTC facilities are reduced to business shells with beds and equipment, lacking the ability to provide essential care. Employees breathe life into the patient care process: Administrators lead and organize care delivery, professional staff administer care, and support staff ensure a seamless care experience.

Federal and State regulations governing employee hiring and retention underscore the importance of this crucial asset. While the Center for Medicare and Medicaid Services (CMS) does not explicitly mandate State or Federal Bureau of Investigation (FBI) criminal background checks, Federal regulations, like 42 CFR §483.13(c), prohibit LTC organizations from hiring individuals with a history of abuse, if known to the facility. CMS, in its State Operating Manual’s (SOM) interpretive guidelines, stresses the necessity for thorough investigations into the past histories of hired individuals.

In the wake of COVID-19, with a renewed focus on safeguarding LTC patients, both State and Federal governments have intensified oversight on employee background investigations. In November 2023, OIG issued a recommendation urging the State of “Louisiana should improve its oversight on nursing homes’ compliance with requirements that prohibit employment of individuals with disqualifying background checks.” Louisiana agreed with OIG's recommendation, prompting the inclusion of background check compliance evaluations in state surveys.

Staff credentialing is in fact a complicated process that should be designed to not only safeguard patients from abuse, but also protect the organization from legal and compliance liabilities. Accordingly, in addition to monitoring employee backgrounds for abuse, LTC organizations should monitor licenses and certifications, verify education and identity, and maintain employee documents such as consents, acknowledgements, agreements, and reviews.  List 1 enumerates common credentialing documents that LTC organizations maintain and monitor to safeguard against legal and compliance consequences:

‍List 1

• Offer Letter
• Professional Liability
• Privacy of Information Agreement
• Employment References
• Payer Enrollment
• Professional License
• Job Description
• Board Certifications
• Employment Application & Agreements
• Verification of Licensure
• Annual Performance 
• Code of Conduct
• Observed Competencies
• Criminal Background Check
• OIG Exclusion List Check
• National Sex Offenders Registry search
• Identity Verification
• Verification of Education/ Certification
• Past Employment Verification
• State Abuse Database search
• Motor Vehicle Records search
• BLS, ALS, PALS Certificates
• CPR Certification
• Vaccination & Immunization
• Chest X-ray
• Driver’s License
• Tax Payers Identification (W-9)
• Employee Eligibility (I-9) Forms
• Auto Insurance
• Acknowledgement of Mandated Reporter
• HIPPA Statement
• Annual HIPAA Training Certification

As employee credentialing and qualification verification become focal points for regulators, it is imperative that LTC organizations begin organizing their staff credentialing management processes. 

Benefits of Proper Staff Credentialing Management:

‍Patient Safety:

• Competent Care Delivery: Credentialing ensures that the staff possess the necessary qualifications and skills to navigate the complexities of patient care. This directly contributes to the safety of patients by ensuring that they are in the hands of professionals who can competently address their healthcare needs.

• Emergency Preparedness: Credentialing programs often include training in emergency response. Staff with proper credentials are better equipped to handle unforeseen situations, minimizing risks and promoting a safer healthcare environment for patients.

‍Payments:

• Reimbursement Compliance: Credentialing is often linked to reimbursement processes. Many healthcare systems and insurance providers require proof of staff qualifications for payment processing. Ensuring that caregivers are credentialed helps nursing homes and home health care agencies maintain compliance with reimbursement standards.

• Financial Stability: Properly credentialed staff contribute to the financial stability of healthcare facilities. By meeting the necessary standards, facilities are more likely to receive timely and full payments, fostering a sustainable financial model that allows for continued investment in quality care.

‍Liability:

• Risk Mitigation: Credentialing acts as a proactive measure in risk mitigation. Facilities that employ credentialed staff demonstrate a commitment to quality and safety, reducing the likelihood of legal challenges or liability issues associated with inadequate care.

• Compliance with Regulations: Credentialing ensures that staff adhere to regulatory standards. This compliance not only reduces the risk of liability but also establishes a foundation for legal defensibility in case of unforeseen circumstances.

‍Quality of Care:

• Continuous Professional Development: Staff credentialing often involves ongoing education and training. This commitment to continuous professional development ensures that caregivers stay abreast of advancements in healthcare, contributing to an elevated standard of care. 

• Patient-Centered Approach: Credentialed staff are better positioned to provide patient-centered care. Their qualifications enable them to tailor their services to meet the unique needs of each patient, enhancing the overall quality of care delivered in nursing homes and home health care settings.

Compliance with current survey requirements is challenging, and heightened staff credentialing scrutiny adds pressure to the LTC workforce. Managing caregiver credentialing processes generates numerous due dates and emails. For organizations with 100 employees, administrators may annually handle over 18,000 due dates, emails, and task assignments, spending over 800 hours. However, caregiver credentialing management doesn't have to be complex; software solutions like Perla simplify processes, reducing the administrative burden while ensuring organization, security, and HIPAA compliance. Perla, as a HIPAA-compliant platform, automates due date tracking, reminder emails, task assignments, and provides view access to surveyors if necessary. It streamlines the staff credentialing process, saving organizations thousands of dollars annually. Additionally, by incorporating Perla to manage their caregiver credentialing processes, LTC organizations can securely store and track employee documents in a centrally maintained, web-based repository and provide access to surveyors with proper permission rights. Explore Perla’s ROI Calculator to discover potential savings for your LTC organization through automation or schedule a demo to see how Perla can help you save time and costs in your staff credentialing management.

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