How to Monitor Healthcare Licenses at the Primary Source

Primary Source Monitoring
A healthcare license is a privilege and not a right. By that we mean one must earn a professional healthcare license and keep this license in good standing throughout their practicing career. From a human resource standpoint, the process of keeping up with healthcare licenses can be an incredibly taxing, complex and tedious process, and if you aren’t looking in the right place, your organization could be putting yourself at high risk for non-compliance. Let’s take a look at how to maintain and verify licenses from a primary source record, and discuss some of the challenges this can bring.

Healthcare License Verification

There are well over 80 disciplines in healthcare that require a license or certification. These range from a certified nursing assistant (CNA) or medical assistant, to a brain surgeon, and many other professions. The authorized Board of Issuance is considered the primary source of such licenses once all requirements have been met. These requirements may involve graduating from an accredited school or program and/or an examination from a state licensing or certifying board.

Once an individual has successfully met these criteria, a license is issued solely to them. The license is unique and issued to one individual; although an individual can hold multiple licenses, in multiple states. As a standard of best practice, healthcare providers must verify the license of a potential employee at the primary source as part of their pre-hire screening process and during their employment with ongoing monitoring.

Where is the Primary Source for Healthcare Licenses?

The state licensing board is considered a primary source and will be the single place to verify and monitor for renewal, standing, and in some cases, disciplinary actions taken against the individual and/or his/ her license. In order to conduct effective compliance monitoring of licenses, validation at appropriate times is essential.

Be sure to find out how each state lists the different licenses and which website holds the license database for records you may be referencing. Some states have numerous lists for each healthcare license, and some include all the licenses in just one database. This process can become very time-consuming if done manually, and you leave yourself vulnerable to human error.

ProviderTrust has developed software solutions that do the heavy lifting of verification for you by keeping track of thousands of credentials all in one convenient dashboard.

How Does ProviderTrust's Healthcare License Verification Work?

Three easy steps to protect your organization:
  1. When a license is entered into the system, it will be verified at the primary source.
  2. As the license is approaching expiration, our team verifies the license at least ten days prior to the expiration date. If not renewed, we will send daily updates up to five days past due, and then changes to a monthly schedule, and finally a quarterly verification.
  3. You’ll be able to monitor the license for sanctions across all 50 states. If a sanction is found that could impact the license, the license will be re-verified to ensure that it is still active and in good standing, and you will be notified.

Healthcare Sanction and Disciplinary Action Verifications

In addition to checking the license status, identifying any sanctions or disciplinary actions is essential for ongoing monitoring to gain a broader context when hiring and employing or contracting individuals for your health system or network. These kinds of records can vary tremendously and are all dependent on the state in which the individual was working.

How to Monitor for Healthcare Sanctions and Disciplinary Actions

Collecting and managing all of the information necessary for sanction monitoring is no small task, just knowing where to look and understanding the schedule in which each state releases records can be an uphill battle. However, in the event a license revocation takes place, more details about the individual employee or provider is very helpful.

Automated healthcare sanction screening can help optimize your workflows because you are paying someone who specializes in searching, scraping, and aggregating data from primary sources for any disciplinary actions.

Sanctions and disciplinary actions technically pertain to each individual, and not the license itself. An individual can be sanctioned but still, have an active license. In reality, you don’t even need to have a license to be sanctioned. It is important to understand the differences between verifying licenses and monitoring for sanctions; these processes are separate but related.

Sanction Screening for Licensed Healthcare Providers

Any penalties placed upon the individual who holds the license may be listed on the verification database, but not always.

Monitoring for sanctions or disciplinary actions can be a bit trickier. This information is published in a variety of forms (newsletters, bulletins, meeting minutes, etc.) and not always on a scheduled basis. Some licensure boards update their information on a monthly basis and make it easier for providers to monitor. Other sources require making a habit of routinely checking for updated information.

Automated tools play a key role in developing smarter provider monitoring in place for catching any discrepancies you might miss on a background check, initial screening, and upon license renewal. With these safeguards in place, you are ensuring the highest quality of human resources and company culture by having a record of any potential disciplinary actions that could lead to a larger issue.

License Revocations Lead to Exclusions or  Terminated Individuals

Did you know that over 43% of all of the Office of Inspector General (OIG) exclusions are related to a license revocation? This means that there are over 28,500 OIG excluded providers that can be linked back to a license revocation or sanction from a state licensing board or other primary sources. Some of these individuals, as you can imagine, have since been removed from their positions and are ineligible to provide care or services furnished by federal or state healthcare dollars.

Additionally, did you know that the average time it takes for a state action to reach the OIG is 173 days – almost 6 months? This can leave major gaps in awareness for human resource professionals and expose each organization to the risk of being fined or penalized for each day an excluded individual is providing care or services.

Multi-state Healthcare Licenses

In today’s mobile and urban-centric society, many healthcare professionals reside in one state (home state) and travel to or practice in multiple (neighboring states). Since a majority of these professionals are nurses, many states have signed on to the Nurse Licensure Compact, which enables multi-state licensure for nurses.

Creating a nursing license monitoring verification process in your compliance plan is best practice. It is important to develop and implement a policy that requires licensure in the state where the employee/provider is working and/or a compact nurse license that ensures the employee/provider is working in a state that participates in the compact. This will significantly mitigate the risk involved with this area of license fraud.

Monitoring your licensed professionals on a monthly basis enables you to find the license revocation or disciplinary action immediately, reducing your risk of not finding out until it reaches the OIG LEIE and becomes an exclusion.

In 2017, the average HHS OIG penalty for an excluded person was $126,738.20. Simply put, you cannot afford to not monitor healthcare licenses on an ongoing basis, not just when it’s time for renewal.

Providers and licensed employees can easily cross over from one state to another and quickly acquire a new professional license. Daniel Levinson, former OIG Inspector General, noted in his comments at the 2018 HCCA Compliance Institute, that the OIG has seen a rise in the number of physicians moving from state to state to continue illegal opioid prescribing practices.

We have seen many examples of licensed professionals moving to another state while their license was under investigation in a former state. There is a myriad of reasons why someone moves from state to state; most are for legitimate reasons and are of no concern, but by checking all states for sanctions and disciplinary actions, every month you can be assured that your licensed professionals have nothing to hide. Meanwhile, your patients are receiving the best quality of care from properly licensed and sanction-free employees.

Smarter Healthcare License Monitoring for a Mobile Workforce  

When you factor in that healthcare has a highly mobile workforce, and many professionals now have multi-state issued licenses, an effective plan must be in place and constantly reviewed to feel confident that your organization is covering all of your bases when it comes to healthcare license and certification management.

The risks continue to grow along with the penalties for non-compliance. Make sure you reduce your risks and monitor your licensed professionals every month to make sure everyone is in good standing and your patients are receiving the care they deserve from properly licensed providers.

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