Governance & Provider Credentialing

MANDATORY

5 criteria

ALL YES Standard likely met. ANY PARTIAL Improvement plan required. ANY NO Blocks accreditation until resolved.

REFERENCES

1. [31] Many older malpractice insurance policies were drafted before telemedicine became mainstream and contain explicit exclusions for virtual care unless a formal endorsement is added, with coverage needing to be affirmatively stated in policy declarations or endorsements, since silence is not protection.

Silence in a policy about telemedicine isn't protection — many older malpractice policies were drafted before virtual care became common and explicitly exclude it unless a formal endorsement is added, meaning a provider who's never specifically confirmed telemedicine coverage could discover, only after a claim arises, that they were never actually covered for the care they were delivering.

1 Coverage is confirmed for the primary provider but not specifically verified for covering or contracted providers.

Every provider delivering care under this service carries the same real requirement for confirmed coverage.

2 Written confirmation exists but doesn't specifically reference telemedicine by name, leaving genuine ambiguity.

Specific, explicit language addressing telemedicine directly is what actually resolves the real ambiguity this criterion exists to prevent.

3 Verification happened at initial policy purchase but hasn't been reconfirmed through a subsequent renewal cycle.

A subsequent renewal is exactly when coverage terms can genuinely change, and deserves the same reconfirmation.

Week 1 Review current malpractice policies for genuine, explicit telemedicine coverage language.

Week 2 Obtain written confirmation from the carrier for any policy lacking explicit telemedicine language.

Week 3 Extend verification to all providers, including covering or contracted staff.

Ongoing Reconfirm coverage at every policy renewal or change.

Ask to see the actual written confirmation of telemedicine coverage, not a general assurance of adequate insurance.

A real, specific document reveals genuine verification, not an assumption of coverage.

Ask when telemedicine coverage was last reconfirmed with the carrier.

A specific, real answer reveals genuine, ongoing practice, not a one-time historical check.

ALL YES Standard likely met. ANY PARTIAL Improvement plan required. ANY NO Blocks accreditation until resolved.

REFERENCES

1. [32] Interstate licensure compacts such as the Interstate Medical Licensure Compact facilitate multi-state licensure but do not inherently standardize malpractice insurance requirements, meaning providers must separately confirm their coverage explicitly extends to every state where they actually deliver care.

Interstate licensure compacts streamline the ability to legally practice across state lines but do not standardize or guarantee malpractice insurance coverage in those same states — a provider could be genuinely, legally licensed to see a patient in a given state while simultaneously lacking any real insurance coverage for care delivered there, and coverage genuinely needs to follow the patient, not simply the provider's practice address.

1 Coverage is confirmed for the provider's most common patient states but not for less frequent ones.

Every state where a patient is genuinely located carries the same real coverage requirement, regardless of frequency.

2 Staff understand the general principle but haven't specifically verified it applies correctly to their own current coverage.

General understanding needs to translate into genuine, specific verification of the provider's own actual policy.

3 A new-state verification process exists but isn't consistently followed under scheduling pressure.

A defined process needs consistent application even under pressure to provide genuine, reliable protection.

Week 1 Review current coverage for genuine, explicit extension to every state where patients are actually located.

Week 2 Establish a proactive verification process before seeing a patient in a genuinely new state.

Week 3 Train staff on the genuine, distinct separation between licensure and insurance coverage.

Ongoing Audit coverage against actual patient location patterns.

Ask how the service would confirm malpractice coverage before a provider sees a patient in a state they haven't seen patients in before.

A specific, confident answer reveals a genuine, proactive process, not an assumption of automatic coverage.

Ask a provider directly whether they understand licensure and malpractice coverage as separate requirements.

A specific, accurate answer reveals genuine understanding, not conflation of the two.

ALL YES Standard likely met. ANY PARTIAL Improvement plan required. ANY NO Requires improvement plan.

REFERENCES

1. [33] When care delivery depends on digital platforms, software malfunctions including failed video platforms, corrupted data transmission, or algorithmic triage tool errors can contribute to patient harm, with traditional malpractice policies often not covering these technology-driven operational failures.

When care delivery genuinely depends on digital platforms, a software malfunction can contribute to patient harm in ways a standard clinical malpractice policy — built around clinical judgment errors — was never actually designed to address, and a service that hasn't specifically confirmed this coverage exists has a real, distinct gap exactly where telemedicine's technology dependence creates its own genuine risk.

1 Coverage was discussed generally with the carrier but the specific scenarios named in this criterion weren't individually addressed.

Genuine confirmation should specifically address concrete scenarios, not remain at a general, unspecific level.

2 Coverage exists for platform failures but hasn't been specifically confirmed for algorithmic or automated triage tool errors.

Every genuinely distinct technology exposure deserves the same specific confirmation, not only the most obvious one.

3 Understanding of coverage scope exists at a leadership level but isn't communicated to providers who might need it in an actual claim.

Providers facing an actual claim need this same genuine understanding, not knowledge confined to leadership alone.

Week 1 Review current malpractice coverage for genuine confirmation of technology-driven failure protection.

Week 2 Raise this specific coverage question directly with the insurance carrier, addressing concrete scenarios.

Week 3 Document the service's specific understanding of coverage scope.

Ongoing Communicate this understanding to providers, not leadership alone.

Ask whether the specific question of technology failure coverage was ever directly raised with the carrier.

A specific, real answer reveals genuine confirmation, not an assumption based on general policy language.

Ask a provider whether they understand what would happen, insurance-wise, if a platform failure contributed to a patient harm event.

A specific, thoughtful answer reveals genuine, communicated understanding, not knowledge confined to leadership alone.

ALL YES Standard likely met. ANY PARTIAL Improvement plan required. ANY NO Blocks accreditation until resolved.

REFERENCES

1. [34] Direct verification of provider credentials with the issuing licensing authority, distinct from acceptance of self-reported documentation, is established as necessary practice, carrying particular importance for remote-only practice arrangements that lack the informal verification opportunities a physical site provides.

A telemedicine service typically has no physical site to visit, no in-person interview process that might otherwise reveal an inconsistency, and no colleague who's worked alongside the provider in a shared physical space — this absence of the informal verification opportunities a physical facility has almost by default means direct, formal credential verification carries genuinely more, not less, real weight.

1 Direct verification happens for licensure but board certification is accepted from self-submitted documentation.

Every credential category carries the same real importance and deserves the same direct verification.

2 Verification is thorough at initial onboarding but isn't reconfirmed as licenses and certifications approach renewal.

A credential's real, current validity depends on genuine reconfirmation, not a historical check alone.

3 Verification happens for full-time providers but is less rigorous for occasional or covering providers.

Every provider actually delivering care carries the same real requirement for genuine, rigorous verification.

Week 1 Review current credential verification for genuine, direct confirmation versus self-report acceptance.

Week 2 Establish direct verification with issuing authorities for licensure, certification, and education.

Week 3 Build a periodic reconfirmation schedule extending to all providers, including occasional staff.

Ongoing Audit verification records for continued currency.

Ask how the service would directly verify a specific provider's board certification, not licensure alone.

A specific, confident answer reveals genuine, complete verification, not licensure-only checking.

Ask when a specific provider's credentials were last reconfirmed.

A specific, real answer reveals genuine, ongoing practice, not a one-time historical check.

ALL YES Standard likely met. ANY PARTIAL Improvement plan required. ANY NO Requires improvement plan.

REFERENCES

1. [35] Defined coverage arrangements for a solo provider's unavailability, distinct from an assumed continuation of care without one, are established as necessary practice for genuine continuity in any single-provider care model, telemedicine included.

Telemedicine's technology removes many of the physical staffing constraints a building would otherwise impose, making genuine solo practice a real, common model here — but this also means the same real, specific vulnerability applies as with any solo practice: without a defined coverage plan, every patient's continuity simply stops the moment the one provider is unavailable, at exactly the moment it might matter most.

1 A coverage plan exists for planned absences but not genuinely for sudden, unplanned unavailability.

A genuine emergency doesn't announce itself in advance, and the plan needs to cover this reality too.

2 An alternative provider is named but the relationship hasn't been recently reconfirmed as still active.

A coverage relationship needs to remain genuinely active, not just historically established.

3 The plan exists but patient awareness relies on them happening to ask, not proactive communication.

Genuine, proactive awareness is more reliable than a plan patients only discover by chance.

Week 1 Review current coverage arrangements for genuine readiness, including sudden, unplanned absence.

Week 2 Establish or reconfirm a specific, named alternative provider relationship.

Week 3 Build proactive patient communication about the coverage plan.

Ongoing Periodically reconfirm the coverage relationship remains genuinely active.

Ask what specifically would happen if the provider became suddenly, unexpectedly unavailable today.

A specific, confident answer reveals a genuine plan, not an assumption it would work out.

Ask a patient directly whether they know what to do if the provider were unavailable.

This tests genuine, proactive awareness, not an assumption patients would figure it out.