Credentialing: CTeL Assesses the Impact of CMS Conditions of Participation on Telehealth

Credentialing and privileging of physicians using telemedicine to deliver healthcare services has long been a key issue for telehealth providers.  When a physician uses telemedicine to direct the care of a patient in a hospital, what steps should the hospital take with regard to credentialing and privileging that physician? 

A potentially significant issue in the area of hospital credentialing has arisen around this question.

The Center for Telehealth and e-Health Law has been advised by telehealth practitioners that the Centers for Medicare and Medicaid (CMS) has emphasized that their Conditions of Participation must be followed to credential physicians at distant telehealth sites. 

CMS does not sanction the Joint Commission’s (JC) approach of allowing one JC accredited facility to recognize the credentialing process of another JC accredited facility.    In 2001, the JC developed these guidelines, which sought to maintain the integrity of the credentialing process for telemedicine, but at the same time, recognize that the efficiency and knowledge of the credentialing process often rested with credentialing at the originating site.

Many in the telehealth field have expressed concern that this CMS decision effectively undercuts the use of telemedicine by requiring credentialing at the distant site of each doctor using telemedicine. 

The Center for Telehealth and e-Health Law has compiled an assessment to gauge the impact on telehealth community of this policy of requiring that CMS’s Conditions of Participation be followed, rather than the JC’s telehealth guidelines.  The findings of this informational assessment will be published at www.telehealthlawcenter.org.

CTeL urges institutions receiving or providing telehealth services that require the credentialing of physicians who provide inpatient or outpatient clinical services be represented in this assessment.


Click here for the CTeL Assessment on Credentialing

Click here to download a PDF of this assessment to facilitate coordination among other individuals.  Please note that the final results of your assessment must be entered through the above link.