The DHHS Health Resources and Services Administration (“HRSA”) has finally published the new National Practitioner Data Bank (“NPDB”) Guidebook. The original Guidebook had not been updated since September 2001.
The updated April 2015 NPDB Guidebook is available here.
The new Guidebook extensively covers the changes resulting from the 2013 merger of the NPDB and the Healthcare Integrity and Protection Data Bank (“HIPDB”). The HIPDB was a separate data bank that received and disclosed reports of final adverse actions by federal and state agencies and health plans against practitioners, entities, providers, and suppliers. After the merger, there were significant changes in the entities eligible to query and report, as well as the individuals and entities subject to reports.
The Guidebook includes a number of tables covering:
- Entities eligible to query and report under the three governing statutes
- Entities qualifying as hospitals and health care entities
- Multiple eligible entity types and differing NPDB reporting and querying requirements by entity
- Practitioners subject to queries and reports
- Health care entities, providers, and suppliers subject to queries and reports
- Reporting requirements and query access
- Information available in queries
- Reportable events
- Time frames for reporting
- Dispute resolution
While the tables are helpful, it is important to closely review the Guidebook’s expanded discussion of how HRSA interprets and applies the querying and reporting requirements to specific entities and situations (including new sections on centralized and delegated credentialing). This is particularly true for the sections on reporting medical malpractice payments and adverse clinical privileges actions. As an example, the Guidebook explains what constitutes an “investigation” related to clinical privileges and when summary suspensions must be reported. The examples and Q&As are considerably expanded and much improved from the original Guidebook.
The new Guidebook also covers reports of federal licensure and certification actions, peer review organization and private accreditation organization actions and findings, exclusions from federal or state health care programs, health care related criminal convictions and civil judgments, and other adjudicated actions and decisions.