What is privileging?
Privileging refers to giving an individual permission or ‘privileges’ to engage in specified clinical activities. ABC defines how a credentialed person may be allowed, under supervision, to provide items and services outside of their scope of practice. That privileging process is described in detail in the ABC Orthotic, Prosthetic and Pedorthic Scope of Practice.
Why is the ability to privilege a non-certified individual being eliminated?
The ABC board of directors feels strongly that the education and training required for certification are critical elements in the provision of safe and effective patient care. We believe this change raises the standard of care and upholds the highest level of patient care services by ABC credential holders.
When does the change take effect?
The change to privileging will take effect January 1, 2019. After that date ABC accredited facilities and certified individuals will no longer be able to privilege a non-credentialed person to provide patient care services.
Are non-certified individuals allowed to provide any services?
Certain patient care tasks can be delegated to non-credentialed individuals. The new definition for Support Personnel details what aspects of patient care can be delegated to non-credentialed persons. For more information, refer to the definition of Support Personnel. This definition goes into effect on January 1, 2019.
What are my options if I currently privilege non-certified individuals?
After January 1, 2019 you will not be able to privilege a non-credentialed person to provide custom fitted or custom fabricated services. You should consider encouraging your non-credentialed staff to become certified as an orthotic or prosthetic assistant, an orthotic fitter or a therapeutic shoe fitter depending on what your practice needs. Non-credentialed individuals will continue to be allowed to provide off-the-shelf items after January 1, 2019.
How will this affect my accreditation?
After January 1, 2019 all ABC accredited facilities will have to comply with the new standards. There will be no impact to your accreditation until that date. You should begin now to review your practice’s policies and procedures if you currently privilege non-credentialed individuals to provide patient care.
Does this change affect the accreditation standards?
Standards HR.6 and HR.6.1 will be revised to reflect the changes to the privileging rules. The revised standards will be published in 2018 prior to their taking effect in January 2019.
How can I modify my current policies to meet the new standards?
If you don’t currently privilege non-credentialed staff to provide patient care services you do not need to make any changes to your practice. If you are currently privileging non-credentialed staff, you need to assess what types of items/services the non-credentialed individuals are providing. If they are only providing off-the-shelf items, they can continue to provide these types of items. If they are providing any services related to custom fitted or custom fabricated items, this change will impact that ability. In order to continue to provide those services, your non-credentialed individuals will need to become certified as an orthotic or prosthetic assistant, an orthotic fitter or a therapeutic shoe fitter. You should also review the new definition of Support Personnel to determine if your practice’s needs can be met within the framework of that definition.
Will current non-certified care providers be grandfathered in so that they can continue to be privileged to provide care?
No, there will be no grandfathering. All ABC accredited facilities and certified individuals will have to comply with the changes to the Scope of Practice beginning January 1, 2019.
My non-certified individual is providing OTS; do they need to be privileged?
No. Off-the-shelf items can be provided by any staff member; no certification is required. Any item that has ‘off-the-shelf’ in the Medicare HCPCS L-code descriptor is considered an off-the-shelf item. This does not include diabetic HCPCS codes (e.g., A5500).