Lurking behind every privileging, licensing and credentialing decision is an inquiry by your hosp8tial, health plans, and nearly any certificating body is a search of the National Practitioner Data Bank (NPDB). The NPDB is a data base run by the US Department of Health and Human Services. It is mandatory for hospitals, state licensing boards, and even health plans and credentialing arms of physician organizations to submit actions of a negative nature to the NPDB. And it is in many cases mandatory that test organizaiton do a search of the NPDB when considering a physician’s application for privileges or crediting and licensing.
Reported to the NPDB are suspensions, terminations, or any restitutions on clinical privileges at a hospital, actions that could impact your license from a state agency (OPMC), malpractice awards, or investigations done by hospitals into any patient care or other matters.
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What’s in the NPDB can impact your ability to be employed, granted privileges at a hospital, or even retain your participating contracts with health plans. What’s there, like a financial credit report, can come back to bite you.
And similar to a financial credit report, what is in the report can be commented upon. Not that the negative finding will be expunged at with the credit report when disputed, but the NPDB does allow physicians to file a statement towards explain the circumstances, or defending one’s reputation.
Sometimes the situations reported are technical violation, and physicians think that unless patient care is involved, the NPDB is of no concern. Not so. For example, the physician that choose to resign from a hospital to take another position was flagged because at the time he was being investigated for an issue related to by-laws of the hospital. No patient care issue, but it was reported and found on a NPDB report because the rule is that resignations during investigations are reportable, regardless of the reason. (The rule supposes that physicians resign to stop an investigation as to avoid negative findings)
What is in your NPDB report follows you, and impacts our reputation. Filing a comment, which must be well worded is important to rehabilitating your reputation as others see it, explaining the circumstances, or otherwise writing to mitigate the damages of a correct finding against you.
Here is where you know what happened, the potential unfairness of the events, the circumstances. Your response has to be carefully structed, and unemotional. A good healthcare lawyer needs to do the wordsmithing with you. The wording has to be just right. Don’t let the drama of the situation get in the way. This should not be a do it yourself response, there is too much riding on it. Once filed, it stays on the NPDB, so words will matter. The last thing you want is to slam your former employer, or come across as a future problem for a future employer.
It is always preferable to have a response to a NPDB filing filed at the time the report to the NPDB is filed. Once a reported has bene filed, whenever you are renewing or applying for certification, license or privileges, the NPDB is going to be queried. Have your response, your side of the issue there as well.