Standard 7 — Governance & Provider Credentialing
Criteria in this standard
7.2 — Malpractice Coverage Genuinely Follows the Patient's State
7.3 — Technology-Driven Operational Failures Are Specifically Covered
7.4 — Provider Credentials Are Verified Directly, Not Accepted on Self-Report
7.5 — A Genuine Coverage Plan Exists for a Solo Provider's Absence
Malpractice Insurance Explicitly Covers Telemedicine
Non-Negotiable
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
If you are starting from zero — do this first
- Ask each provider's insurer, in writing: 'Does this policy cover telemedicine?'
- File the written answer.
- Fix every 'no' or 'unclear' before the provider's next session.
- Re-confirm annually.
Self-assessment questions
Evidence: Malpractice policy telemedicine endorsement documentation
Evidence: Written carrier confirmation
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
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.
Malpractice Coverage Genuinely Follows the Patient's State
Non-Negotiable
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
If you are starting from zero — do this first
- For each provider, ask the insurer: 'Which jurisdictions does this cover?'
- Compare to where they are licensed and see patients.
- Close every gap.
- Reconcile annually.
Self-assessment questions
Evidence: State-specific coverage confirmation
Evidence: N/A — tested directly
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
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.
Technology-Driven Operational Failures Are Specifically Covered
Core
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
If you are starting from zero — do this first
- List your technology failure scenarios: outage, breach, connection failure, vendor failure.
- Ask your broker which are covered.
- Add cyber liability and technology E&O if missing.
- Document the coverage map.
Self-assessment questions
Evidence: Technology failure coverage confirmation
Evidence: N/A — tested directly
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
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.
Provider Credentials Are Verified Directly, Not Accepted on Self-Report
Non-Negotiable
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
If you are starting from zero — do this first
- For each provider, contact the licensing board and verify the licence.
- Contact the certifying body and verify certification.
- Contact the medical school and verify the degree.
- File the evidence.
Self-assessment questions
Evidence: Direct credential verification record
Evidence: N/A — tested directly
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
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.
A Genuine Coverage Plan Exists for a Solo Provider's Absence
Core
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
If you are starting from zero — do this first
- Find another solo provider and propose reciprocal cover.
- Write the absence protocol.
- Arrange records access with patient consent.
- Test it.
Self-assessment questions
Evidence: Coverage arrangement documentation
Evidence: Named alternative provider documentation
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
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.