Medical staff professionals were advised by hospital attorneys years ago (in the early to mid-80’s) that costly, time-consuming hearings could be avoided by developing and utilizing a pre-application process. The theory was that the potential medical staff applicant should be informed “upfront” what qualifications must be met to receive an application for membership, and therefore be considered an “applicant.”
The pre-application was a “screening process” for a practitioner requesting an application for medical staff membership. It was utilized to assure the hospital and medical staff that the potential applicant met the basic minimum criteria for membership (at this point in time, there wasn’t much privileging criteria). In other words, it was felt to be a “waste of time” both for the applicant and hospital, for an application to be accepted by a hospital when the practitioner did not meet minimum criteria for membership.
If an application was accepted, the conventional wisdom was that the application had to be processed, and denied if the applicant didn’t meet the organization’s criteria. If the submission of an application resulted in a denial, the affected practitioner would be entitled to the fair hearing procedures described in the medical staff bylaws.
In a pre-application process, the applicant is required to provide information in order to demonstrate that they meet the minimum criteria for membership and to receive an application. Often, this information is then again requested as part of the application.
We now know that organizations are not required to process an application from any applicant who does not meet organization requirements, and often there are important issues which surface during the verification process that require an explanation of additional information in order to continue processing an application.
Another reason that organizations have eliminated this process or are taking a second look at the pre-application process is that it can often add days to weeks to the time frame that it takes for a new applicant to obtain membership or privileges. The pre-application must be completed and returned, and if the applicant meets criteria, then an application is provided. This process has proved to be another source of frustration for a new applicant who already feels that the credentialing process is burdensome.
Some facilities have decided to streamline the process by providing the applicant with written information outlining the minimum criteria for membership at the time the application is provided. Still other facilities have included the criteria on the first page of the application, with instructions to “stop and do not continue” completing the application if the applicant does not meet criteria. Organizations have gotten much better in recent years (since the introduction of reporting requirements to the National Practitioner Data Bank) of identifying and documenting requirements for membership. CMS and Joint Commission accreditation requirements are prompting many organizations to also refine and clearly state requirements for privileges.
Establishing expectations upfront with new applicants is always wise, and it is important to use every opportunity to communicate with a candidate, so that they will fully understand the credentialing process and become a productive member of the medical staff. Elimination of the pre-application process does not eliminate the necessity for applicants to prove that they meet all organization requirements for membership and/or privileges. We now know that processing of an application can be stopped any time it becomes evident that an applicant does not meet organization requirements. We also know that when an applicant does not meet organization requirements, it is not a denial of membership or privileges. It is a matter of the applicant not meeting “threshold eligibility requirements” and, therefore, no fair hearing process is applicable.