It used to be only forward-thinking healthcare organizations that produced plans and policies reflecting their preparation for disasters or emergencies. It’s no longer just an interesting undertaking—to educate about and create a complete plan to avoid the unqualified provision of patient care, despite the swirling chaos of a situation.
Today, it seems as if disasters of nature or human making hit hospitals and the communities in which they operate with regular frequency, even if most hospitals rarely must trigger a full-on Emergency Operation Plan (EOP).
Depending on your organization’s bylaws and policies and procedures, the definition of disaster privileges may vary. For many, disaster privileges are not the same as emergency or temporary privileges, although all refer to privileges in effect for an abbreviated period of time and/or that are granted on an accelerated timeline.
Do the following sample definitions for accelerated or time-limited clinical privileges differ from the definitions for contingencies at your organization?
Disaster privileges: Granted to qualified practitioners who don’t hold privileges at an organization or site where they will volunteer services after the hospital has activated its emergency operations plan and when it needs additional clinicians to meet immediate patient or community needs. Typically, weather or another major crisis creates a situation that overwhelms the organization’s internal capabilities to provide its typical breadth of care. Individuals granted disaster privileges must be eligible based on the criteria as outlined in the medical staff bylaws or P&Ps. Those documents must indicate which individual(s) or committee(s) may grant disaster privileges, under what circumstances, what the process is for granting and monitoring disaster privileges, and when the privileges expire. Disaster privileges are temporary, but they allow privileged practitioners to care for patients for as long as needed during the course of the event.
The Centers for Medicare & Medicaid Services (CMS) and National Committee for Quality Assurance’s (NCQA) regulations don’t contain language on disaster privileging, while Det Norske Veritas (DNV) and Healthcare Facilities Accreditation Program (HFAP) use the same language for disaster and emergency privileges. The Joint Commission guides on disaster privileges and has a list of specific requirements that must be met to grant such privileges to a licensed independent practitioner.
Emergency privileges: Clinical privileges that extend beyond those currently held by a member of the medical staff so that they may provide care, treatment, or services to a patient as a life-saving action or to prevent serious harm—as long as the care, treatment, and services are within the scope of the practitioner’s license. As soon as the emergency has abated, the patient’s care turns over to a provider with appropriate privileges (or care stays with that provider if the ongoing care needed falls within their scope of privileges). As with disaster privileges, criteria must be outlined in the medical staff bylaws or policies and procedures
Temporary privileges: In general, temporary privileges may be granted in two circumstances: to fulfill an important patient care need, and for initial applicants or initial privileges with a complete application that raises no concerns. The CMS is silent on the granting of temporary privileges but widely interpreted to guide that there should be no abbreviation for the privileging process and organizations must follow their bylaws or policies and procedures when obtaining governing body approval for temporary privileges
- Follow this link for a Sample Disaster Privileges Policy/procedure and application. Credit to Kathy Matzka, CPMSM, CPCS, an Illinois-based, leading independent consultant and speaker on credentialing and privileging topics.
- Click here for an HCPro/BLR article with sample policy language for granting temporary privileges.
- Use this link to access a quick reference guide to TJC’s emergency management requirements across multiple setting plus key questions for hospitals concerning their collaborative emergency management efforts.