Proactive Disclosure Service Prototype (PDS)


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Overview

The PDS was developed in response to a growing interest in continuous monitoring of health care practitioners. Entities that subscribe to the PDS will receive notification within one business day of the Data Banks’ receipt of a report on any of their enrolled practitioners. Notice will be provided via e-mail and PDS notification via the Options screen in the IQRS.

This service is offered as an alternative to the current Data Bank querying service. Entities may continue to query on practitioners, enroll all practitioners in the PDS, or enroll some practitioners in the PDS while continuing to query on others.

The PDS meets legal and accreditation requirements for querying the National Practitioner Data Bank (NPDB). As long as the practitioner remains enrolled in the PDS the entity has met the requirement to query. Enrollment confirmation may be used to demonstrate compliance with accreditation standards including continuous monitoring. The format and the information contained in the Data Bank report, as well as the information required to be reported to each Data Bank, will remain the same.

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Participation in the PDS

All eligible entities who query the Data Banks are invited to participate in the PDS. Approximately 600 entities are currently participating in the PDS. To participate in the PDS, the Entity Data Bank Administrator must log in to the IQRS, click Activate Proactive Disclosure Service (PDS) on the Administrator Options screen and follow the on-screen instructions. Enrollment for each Data Bank is determined by the entity’s registration, which is based on its statutory authority to query.

Practitioners may be enrolled in the PDS through the IQRS, the Querying and Reporting XML Service (QRXS), or the Interface Control Document (ICD) Transfer Program (ITP). Enrolling practitioners through the IQRS enables users to enroll a single subject, a stored subject, or a subject from the subject database.

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Duration

The Prototype will last at least 18 months to determine system functionality and viability throughout an entire enrollment period of one year including the renewal process. Entities may subscribe to PDS and enroll practitioners during the Prototype phase. Therefore, in order to provide entities with a full year of service, including the opportunity to renew, the Prototype period will naturally extend beyond one year.

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Federal Querying Requirements and Accreditation Standards

Since the PDS provides continuous querying, enrollment in the PDS meets the mandatory hospital querying requirements of the Health Care Quality Improvement Act of 1986, as amended.

The Joint Commission supports the PDS "as an acceptable alternative to directly querying the NPDB."

The National Committee for Quality Assurance (NCQA) has indicated the PDS may be used to review malpractice settlements or judgments paid on behalf of a practitioner at initial credentialing (CR3) and recredentialing (CR7); verify sanctions and limitations on licensure and Medicare/Medicaid sanctions at initial credentialing (CR5) and recredentialing (CR7); and conduct continuous monitoring of sanctions and limitations on licensure and Medicare/Medicaid sanctions (CR9).

Centers for Medicare & Medicaid Services (CMS) views the use of the PDS as consistent with CMS hospital requirements for quality assessment and medical staff privileging.

The Commission on Accreditation of Rehabilitation Facilities (CARF) recognizes PDS "as one source of data that may be used by providers of medical rehabilitation services as part of a professional privileging system."

URAC recognizes PDS as an acceptable alternative method of querying the NPDB. URAC has indicated that the PDS may be used to verify information on a healthcare provider at initial credentialing (CR 1) and recredentialing (CR 15) as well as conduct continuous querying of compliance with credentialing criteria [CR 14(a)] for the following: malpractice settlements or judgments paid on behalf of a practitioner; sanctions and limitations on licensure; Medicare/Medicaid participation and sanctions; hospital or other healthcare entity privileges; and membership in professional societies.

View the recognition letters from URAC, The Joint Commission, NCQA, and CARF.

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Subscription Fee

The annual PDS enrollment fee covers the cost of the enrollment of one practitioner in one Data Bank for one year. When an entity initially enrolls a practitioner in the PDS, the entity will receive a copy of any active report(s) that the practitioner may have in the Data Bank(s).

For billing purposes, each practitioner enrolled in a particular month will have an enrollment that expires on the last day of the same month of the following year (i.e., all practitioners enrolled in January 2007 regardless of the exact date of enrollment, have an expiration date of January 31, 2008). The subscription fee is payable at the time of enrollment and enrollment renewal. The annual PDS enrollment fee for each Data Bank will be $3.25, as announced in the Federal Register Notices. This rate is subject to change after the prototype period is complete.

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Canceling a PDS Subject Enrollment

You must cancel any PDS enrollment immediately upon receiving notice that the subject has left your organization. PDS cancellations may be scheduled in advance. Failure to cancel enrollment of a subject that is no longer part of your organization could result in a violation of the confidentiality provisions of the Health Care Quality Improvement Act of 1986, as amended, and may result in a civil money penalty. The Privacy Act also contains penalties for confidentiality breaches of Data Bank information.

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Additional Information on the PDS