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International Accreditation of Healthcare Facilities

ASF Standards · Telemedicine · Standard 7

Standard 7 — Governance & Provider Credentialing

5 criteria · 3 non-negotiable · 2 core · Version 3.0

Criteria in this standard

7.1

Malpractice Insurance Explicitly Covers Telemedicine

Non-Negotiable

Every provider's malpractice insurance explicitly, affirmatively states coverage for telemedicine practice — not assumed included in a standard policy that predates telemedicine becoming mainstream, given many such older policies contain explicit exclusions for virtual care absent a specific endorsement.

In plain terms: Every provider's malpractice insurance policy explicitly says it covers telemedicine — in writing, not assumed from a general policy.

Facility category Crisis Transition Small Standard
Applicability Full Full Full Full

Why this matters

Many malpractice policies were written for in-person practice. Some exclude telemedicine; some cover it only in the provider's home jurisdiction; some are silent, which means a dispute at the worst possible time. A provider without confirmed telemedicine coverage is practising uninsured — and a claim would fall on them personally, and potentially on the service. The service must obtain, for each provider, written confirmation from the insurer that telemedicine practice is covered, and must file it and renew it.

What good looks like

  • Every policy explicitly, affirmatively states telemedicine coverage.
  • Coverage is genuinely confirmed in writing with the carrier.
  • Verification is genuinely reconfirmed at every renewal or policy change.

Common failure modes

  • Telemedicine coverage is assumed from a standard policy's silence on the matter.
  • Confirmation, if any, is verbal, not documented in writing.
  • Coverage was verified once and never reconfirmed at renewal.

Worked example

In practice
A 14-clinician telemedicine service.
BeforeProviders had malpractice insurance. Nobody had checked whether it covered telemedicine. When the compliance lead asked insurers, three policies excluded telemedicine entirely and four covered it only in the provider's home state.
ActionEach provider obtained written confirmation from their insurer of telemedicine coverage, or a rider adding it, or a new policy. The confirmations are filed with expiry dates. The service's own entity policy was reviewed and amended to explicitly cover telemedicine operations. Annual re-confirmation is required.
AfterThe Monitor reviewed 14 written coverage confirmations and the entity policy with telemedicine endorsement. Verified.

If you are starting from zero — do this first

  1. Ask each provider's insurer, in writing: 'Does this policy cover telemedicine?'
  2. File the written answer.
  3. Fix every 'no' or 'unclear' before the provider's next session.
  4. Re-confirm annually.
The most common mistake: Assuming a malpractice policy covers telemedicine because it covers medicine.

Self-assessment questions

1. Does every provider's malpractice policy explicitly, affirmatively state coverage for telemedicine practice? — Real, affirmative confirmation in the policy itself, not an assumption based on a standard policy's silence.
Evidence: Malpractice policy telemedicine endorsement documentation
2. Has this coverage been genuinely confirmed in writing with the insurance carrier, not assumed from a verbal assurance? — Real, written confirmation, not a verbal representation alone.
Evidence: Written carrier confirmation
3. Is this verification genuinely reconfirmed when a provider's policy renews or changes, not treated as a one-time check? — Real, periodic reconfirmation, not verification assumed to remain valid indefinitely.
Evidence: Renewal reconfirmation record

Common reasons for a PARTIAL answer

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

Implementation plan

When What
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.

How the Monitor verifies this

Method What Detail
DOCUMENT Policy endorsement review Reviews the actual policy documentation for genuine, affirmative telemedicine coverage.
DOCUMENT Written confirmation review Reviews evidence of genuine, written carrier confirmation, not verbal assurance alone.
DOCUMENT Renewal reconfirmation review Reviews whether coverage is genuinely reconfirmed at each policy renewal or change.

Supervisor tips

  • 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.

Evidence base

[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.

ASF training courses on GMJ Academy →

Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.

7.2

Malpractice Coverage Genuinely Follows the Patient's State

Non-Negotiable

Malpractice coverage genuinely, explicitly extends to every state where a patient is actually located during care — not assumed sufficient because a provider is licensed there through an interstate compact, given compact licensure and malpractice insurance are genuinely separate, unlinked requirements.

In plain terms: Malpractice coverage explicitly extends to every jurisdiction where a patient is located during care — not just the provider's home jurisdiction.

Facility category Crisis Transition Small Standard
Applicability Full Full Full Full

Why this matters

A policy that covers telemedicine 'in the state where the provider is licensed and located' does not cover the patient across the border. If the patient is harmed and sues in their jurisdiction, the policy may not respond. Coverage must follow the patient: every jurisdiction in the licensure matrix (2.1) must be a jurisdiction where the policy applies. The insurer confirms this in writing; the service reconciles the licensure matrix against the coverage territory; any gap is closed by endorsement or by not serving that jurisdiction.

What good looks like

  • Coverage genuinely, explicitly extends to every state where patients are actually located.
  • Coverage is genuinely verified separately from licensure compliance.
  • A proactive process confirms coverage before seeing a patient in a new state.

Common failure modes

  • Coverage is assumed sufficient based on compact licensure alone.
  • Insurance verification is conflated with licensure compliance, not separately confirmed.
  • Coverage gaps are discovered only after care has already been delivered in a new state.

Worked example

In practice
A telemedicine service with providers licensed across multiple jurisdictions.
BeforeMalpractice coverage was confirmed for telemedicine (7.1) but the territory was not checked. Several policies covered only the provider's home state. Providers were seeing patients in states where they were licensed but not insured.
ActionFor each provider, the insurer confirmed the coverage territory in writing. The licensure matrix was reconciled against it. Gaps were closed by policy endorsement extending territory, or by removing the uninsured jurisdictions from the provider's scheduling eligibility. The reconciliation is repeated annually and when licensure changes.
AfterThe Monitor reviewed the territory confirmations, the reconciled matrix, and the scheduling configuration matching insured territory. Verified.

If you are starting from zero — do this first

  1. For each provider, ask the insurer: 'Which jurisdictions does this cover?'
  2. Compare to where they are licensed and see patients.
  3. Close every gap.
  4. Reconcile annually.
The most common mistake: Licensed in five states, insured in one.

Self-assessment questions

1. Does malpractice coverage genuinely, explicitly extend to every state where patients are actually located? — Real, specific, state-by-state confirmed coverage, not assumed from compact licensure alone.
Evidence: State-specific coverage confirmation
2. Is coverage genuinely verified separately from licensure, not treated as automatically bundled together? — Real, distinct verification of insurance coverage, not conflated with licensure compliance.
Evidence: N/A — tested directly
3. Is there a specific process for confirming coverage before a provider sees a patient in a genuinely new state? — A real, proactive verification process, not discovering a coverage gap only after care has already been delivered.
Evidence: New-state coverage verification process

Common reasons for a PARTIAL answer

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

Implementation plan

When What
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.

How the Monitor verifies this

Method What Detail
DOCUMENT State-specific coverage review Reviews evidence that malpractice coverage explicitly extends to every state where patients are actually located.
ASK Licensure-insurance distinction interview Asks staff whether they understand licensure and insurance coverage as genuinely separate requirements.
DOCUMENT New-state verification process review Reviews the process for confirming coverage before a provider sees a patient in a new state.

Supervisor tips

  • 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.

Evidence base

[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.

ASF training courses on GMJ Academy →

Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.

7.3

Technology-Driven Operational Failures Are Specifically Covered

Core

Insurance coverage specifically addresses technology-driven operational failures — a failed video platform, corrupted data transmission, an algorithmic triage tool error contributing to patient harm — not assumed included within standard clinical malpractice coverage, given traditional malpractice policies often don't cover this genuinely distinct category of exposure.

In plain terms: The service's insurance specifically covers technology failures — a platform outage, a data breach, a failed connection during an emergency — not just clinical negligence.

Facility category Crisis Transition Small Standard
Applicability N/A Full Adapted Full

Why this matters

Telemedicine has failure modes that in-person care does not: the platform goes down for a day and 200 appointments are missed; a data breach exposes thousands of records; the connection drops during an emergency and the patient is harmed by the delay. General and malpractice insurance may not cover these. Cyber liability, business interruption, and technology errors-and-omissions coverage address them. The service should review its policies against a list of technology failure scenarios and confirm coverage for each in writing.

What good looks like

  • Coverage for technology-driven operational failures is specifically confirmed, not assumed.
  • This coverage question was genuinely raised and directly confirmed with the carrier.
  • The service understands the specific scope of what this coverage addresses.

Common failure modes

  • Technology failure coverage is assumed included within standard clinical malpractice.
  • This specific question was never raised with the carrier; silence is treated as inclusion.
  • The service has no specific understanding of what technology-related coverage actually includes.

Worked example

In practice
A telemedicine service with malpractice and general liability insurance only.
BeforeNo cyber liability, no business interruption, no technology E&O. When the video platform suffered an outage that cancelled a day of appointments, the loss was uninsured. When the service considered a data breach scenario, it realised it had no coverage for notification costs or regulatory penalties.
ActionAn insurance broker reviewed the service against a technology failure scenario list: platform outage, data breach, ransomware, connection failure causing harm, vendor failure. Cyber liability and technology E&O policies were added. Business interruption was extended to platform outage. The coverage map is documented and reviewed annually.
AfterThe Monitor reviewed the coverage map with policies matched to scenarios, and the new cyber and technology E&O policies. Verified.

If you are starting from zero — do this first

  1. List your technology failure scenarios: outage, breach, connection failure, vendor failure.
  2. Ask your broker which are covered.
  3. Add cyber liability and technology E&O if missing.
  4. Document the coverage map.
The most common mistake: Assuming malpractice insurance covers a data breach — it does not.

Self-assessment questions

1. Does insurance coverage specifically address technology-driven operational failures? — Real, specific confirmation, not an assumption it's automatically included.
Evidence: Technology failure coverage confirmation
2. Has this coverage question been genuinely raised and confirmed with the carrier? — Real, direct confirmation, not silence interpreted as inclusion.
Evidence: N/A — tested directly
3. Does the service understand which technology failure scenarios this coverage would and would not address? — Real, specific understanding, not an assumption of broad protection.
Evidence: Coverage scope understanding documentation

Common reasons for a PARTIAL answer

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

Implementation plan

When What
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.

How the Monitor verifies this

Method What Detail
DOCUMENT Technology coverage confirmation review Reviews evidence that technology-driven failure coverage was specifically confirmed, not assumed.
ASK Carrier confirmation interview Asks staff whether this specific coverage question was genuinely raised with the insurance carrier.
DOCUMENT Scope understanding review Reviews the service's documented understanding of what this coverage does and doesn't address.

Supervisor tips

  • 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.

Evidence base

[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.

ASF training courses on GMJ Academy →

Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.

7.4

Provider Credentials Are Verified Directly, Not Accepted on Self-Report

Non-Negotiable

Every remote provider's credentials — licensure, board certification, education — are verified directly with the issuing authority, not accepted based on the provider's own self-reported documentation, given the absence of a physical site visit that might otherwise surface an inconsistency makes this direct verification genuinely more important, not less.

In plain terms: Every remote provider's licence, board certification, and education are verified directly with the issuing bodies — not accepted from their CV or a scanned certificate.

Facility category Crisis Transition Small Standard
Applicability Full Full Full Full

Why this matters

A remote provider may never be met in person. Their credentials are documents on a screen. Fraud is easier and detection harder. Primary source verification — contacting the licensing board, the certification body, the medical school — is the only way to know the provider is who they say they are and qualified as they claim. It is done before the first session, documented, and repeated at licence renewal. The service that accepts a scanned certificate has verified that a scan exists.

What good looks like

  • Every provider's credentials are genuinely, directly verified with issuing authorities.
  • Verification genuinely covers licensure, certification, and education together.
  • Verification is genuinely, periodically reconfirmed, not a one-time check.

Common failure modes

  • Credentials are accepted based on provider self-report without direct verification.
  • Verification covers licensure alone, missing certification or education.
  • Verification happened once at hire and was never reconfirmed.

Worked example

In practice
A telemedicine service that had recruited 16 providers remotely.
BeforeCredentials were accepted from CVs and scanned certificates. Nobody had contacted a licensing board. An audit with primary source verification found one provider's board certification had lapsed and another's claimed fellowship did not exist.
ActionPrimary source verification was completed for every provider: licence with each licensing board; board certification with the certifying body; education with the institution; work history with two prior employers. Findings were documented; the two discrepancies were addressed. Verification is repeated at each licence renewal and annually for certification. A credentials file exists for every provider.
AfterThe Monitor reviewed 16 credentials files with primary source verification evidence and dates. Verified.

If you are starting from zero — do this first

  1. For each provider, contact the licensing board and verify the licence.
  2. Contact the certifying body and verify certification.
  3. Contact the medical school and verify the degree.
  4. File the evidence.
The most common mistake: Verifying that a certificate exists rather than that it is genuine.

Self-assessment questions

1. Are every provider's credentials genuinely verified directly with the issuing authority, not accepted on self-report? — Real, direct verification, not trust in documentation the provider submitted themselves.
Evidence: Direct credential verification record
2. Does this verification genuinely cover licensure, board certification, and education, not licensure alone? — Complete, genuine verification across every relevant credential type, not a partial check.
Evidence: N/A — tested directly
3. Is verification genuinely reconfirmed periodically, not treated as a one-time check at initial hire? — Real, periodic reconfirmation, not verification assumed to remain valid indefinitely.
Evidence: Periodic reconfirmation schedule

Common reasons for a PARTIAL answer

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

Implementation plan

When What
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.

How the Monitor verifies this

Method What Detail
DOCUMENT Direct verification review Reviews evidence of genuine, direct verification with issuing authorities for every provider.
DOCUMENT Credential completeness review Reviews whether verification genuinely covers licensure, certification, and education together.
DOCUMENT Reconfirmation schedule review Reviews whether verification is genuinely, periodically reconfirmed.

Supervisor tips

  • 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.

Evidence base

[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.

ASF training courses on GMJ Academy →

Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.

7.5

A Genuine Coverage Plan Exists for a Solo Provider's Absence

Core

For a service staffed by a single provider, a genuine, defined coverage arrangement exists for when that provider is unavailable — illness, leave, emergency — with a real, named alternative for patients needing care in that gap, not an assumption that patients will simply wait or seek care elsewhere on their own.

In plain terms: If the service has one provider, there is a written arrangement for who covers when they are ill or away — and patients know how to reach care.

Facility category Crisis Transition Small Standard
Applicability Adapted Full Full Full

Why this matters

This is the telemedicine version of PHC 7.1: a solo provider's absence is a service closure unless there is cover. Patients with ongoing care, prescriptions, and crises need someone. Coverage means a named provider or service who will see the patients, access to records, a message to patients about how to reach cover, and a test of the arrangement before it is needed.

What good looks like

  • A genuine, defined coverage arrangement exists and is real, not theoretical.
  • A specific, named alternative provider is identified for coverage gaps.
  • Patients are genuinely, proactively aware of the coverage plan.

Common failure modes

  • No defined coverage arrangement exists beyond an assumption patients will manage.
  • No specific alternative is identified; patients are vaguely told to seek care elsewhere.
  • Patients only learn about coverage gaps when they actually encounter one.

Worked example

In practice
A single-provider telemedicine psychiatry service with 300 patients.
BeforeWhen the provider was hospitalised for two weeks, the service stopped. Patients could not reach anyone. Prescriptions expired. One patient in crisis contacted the service's email and received no reply.
ActionA reciprocal coverage agreement was signed with another solo telemedicine psychiatrist: each covers the other's urgent needs, prescription renewals, and crisis contacts during absence. Records access was arranged with patient consent. An absence protocol names who activates cover, the message patients receive, and how the covering provider is reached. It was tested with a planned absence.
AfterThe Monitor reviewed the signed agreement, the absence protocol, the records access arrangement, and the test record. Verified.

If you are starting from zero — do this first

  1. Find another solo provider and propose reciprocal cover.
  2. Write the absence protocol.
  3. Arrange records access with patient consent.
  4. Test it.
The most common mistake: A solo provider with no cover — the service does not exist when they are ill.

Self-assessment questions

1. Does a genuine, defined coverage arrangement exist for when a solo provider is unavailable? — A real, specific arrangement, not an assumption that patients will manage without care.
Evidence: Coverage arrangement documentation
2. Is there a real, named alternative provider or service patients can be directed to during a coverage gap? — A specific, real alternative, not a vague suggestion to seek care elsewhere.
Evidence: Named alternative provider documentation
3. Are patients genuinely informed of the coverage plan, not left to discover it only when they need it? — Real, proactive patient awareness, not information they only encounter during an actual gap.
Evidence: N/A — tested directly

Common reasons for a PARTIAL answer

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

Implementation plan

When What
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.

How the Monitor verifies this

Method What Detail
DOCUMENT Coverage plan review Reviews the actual, defined coverage arrangement for when the sole provider is unavailable.
DOCUMENT Alternative provider review Reviews the specific, named alternative provider or service patients would be directed to.
ASK Patient awareness interview Asks a patient whether they know what to do if the service's provider were unavailable.

Supervisor tips

  • 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.

Evidence base

[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.

ASF training courses on GMJ Academy →

Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.

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