VA Health Care: Improvements Made in Physician Privileging
Policies, but Medical Facility Compliance Has Not Been Assessed
(06-NOV-07, GAO-08-271T).
In a report issued in May 2006, GAO examined compliance with the
Department of Veterans Affairs' (VA) physician credentialing and
privileging requirements at seven VA medical facilities GAO
visited. VA's credentialing process is used to determine whether
a physician's professional credentials, such as licensure, are
valid and meet VA's requirements for employment. VA's privileging
process is used to determine which health care services or
clinical privileges, such as surgical procedures, a VA physician
is qualified to provide to veterans without supervision. Although
GAO cannot generalize from its findings, GAO found that the seven
facilities were complying with credentialing requirements.
However, the facilities were not complying with aspects of
certain privileging requirements. To better ensure that VA
physicians are qualified to deliver care safely to veterans, GAO
made three recommendations to improve VA's privileging of
physicians. GAO was asked to testify on (1) how VA credentials
and privileges physicians working in its medical facilities and
(2) the extent to which VA has implemented the three
recommendations made in GAO's May 2006 report that address VA's
privileging requirements. To update its issued work, GAO reviewed
VA's policies, procedures, and correspondence related to
physician privileging and interviewed VA central office officials
to determine if the recommendations made in GAO's May 2006 report
were implemented.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-08-271T
ACCNO: A77968
TITLE: VA Health Care: Improvements Made in Physician
Privileging Policies, but Medical Facility Compliance Has Not
Been Assessed
DATE: 11/06/2007
SUBJECT: Health care facilities
Health care personnel
Health care services
Internal controls
Licenses
Noncompliance
Performance measures
Personnel qualifications
Physicians
Policy evaluation
Quality assurance
Veterans benefits
Veterans' medical care
Health policies
Policies and procedures
******************************************************************
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GAO-08-271T
* [1]Background
* [2]VA's Credentialing and Privileging Processes
* [3]Credentialing Process
* [4]Privileging Process
* [5]VA Has Addressed All GAO Physician Privileging Recommendatio
* [6]Contacts and Acknowledgments
* [7]Order by Mail or Phone
* [8]PDF6-Ordering Information-Young-10-25-07.pdf
* [9]GAO's Mission
* [10]Obtaining Copies of GAO Reports and Testimony
* [11]Order by Mail or Phone
* [12]To Report Fraud, Waste, and Abuse in Federal Programs
* [13]Congressional Relations
* [14]Public Affairs
Testimony
Before the Committee on Veterans' Affairs, U.S.Senate
United States Government Accountability Office
GAO
For Release on Delivery
Expected at 9:30 a.m. EST
Tuesday, November 6, 2007
VA HEALTH CARE
Improvements Made in Physician Privileging Policies, but Medical Facility
Compliance Has Not Been Assessed
Statement of Randall B. Williamson
Acting Director, Health Care
GAO-08-271T
Mr. Chairman and Members of the Committee:
I am pleased to be here today as you discuss physician hiring practices at
medical facilities operated by the Department of Veterans Affairs (VA). VA
has over 36,000 physicians working at more than 1,300 facilities in its
health care system. To help ensure the quality of the health care these
physicians deliver and the safety of veterans, VA is responsible for
determining that its physicians have the appropriate professional
credentials and clinical experience to provide health care to VA's
patients. To do this, VA requires physicians to undergo credentialing and
privileging. VA's credentialing process is used to determine whether a
physician's professional credentials, such as licensure, education, and
training, are valid and meet VA's requirements for employment. VA's
privileging process is used to determine which health care services or
clinical privileges, such as surgical procedures or administering
anesthesia, a VA physician is qualified to provide to veterans without
supervision. VA physicians must be credentialed and privileged when they
apply to work in VA--which is known as initial appointment--and at least
once every 2 years thereafter when they must reapply for a position on the
facility's medical staff. These subsequent reviews are known as the
process of reappointment.
In a report we issued in May 2006, we examined compliance with select
credentialing and privileging requirements at seven VA medical facilities
we visited and made three recommendations designed to improve aspects of
privileging and oversight of the process. Although we cannot generalize
from our findings, we found that these facilities were complying with
credentialing requirements. However, they were not complying with aspects
of certain privileging requirements.^1 For example, VA medical facilities
were not submitting information on paid medical malpractice claims within
the 60-day required time frame to VA's office that reviews the claims
information and makes a determination about whether physicians involved in
the claims delivered substandard care to veterans. VA generally agreed
with our findings, conclusions, and recommendations.
^1GAO, VA Health Care: Selected Credentialing Requirements at Seven
Medical Facilities Met, but an Aspect of Privileging Process Needs
Improvement, [15]GAO-06-648 (Washington, D.C.: May 25, 2006), and VA
Health Care: Patient Safety Could be Enhanced by Improvements in
Employment Screening and Physician Privileging Practices, [16]GAO-06-760T
(Washington, D.C.: June 15, 2006).
Today, I will discuss the progress VA has made in implementing our May
2006 recommendations to address noncompliance with VA's privileging
requirements. Specifically, I will discuss (1) how VA credentials and
privileges physicians working in its medical facilities and (2) the extent
to which VA has implemented the three recommendations made in our May 2006
report that address VA's privileging requirements.
To perform our 2006 review, we selected four of VA's credentialing
requirements for review because they are requirements that--unlike
others--address information about physicians that can change or be updated
with new information periodically. As a result, VA requires that this
information be verified by medical facility officials when a physician
initially applies for employment at VA and at least every 2 years
thereafter. Under the four requirements we reviewed, VA medical facility
officials must
1. verify that all state medical licenses held by physicians are
valid;
2. query the Federation of State Medical Boards (FSMB) database to
determine whether physicians had disciplinary action taken against
any of their licenses, including expired licenses;
3. verify information provided by physicians on their involvement
in medical malpractice claims at a VA or non-VA facility; and
4. query the National Practitioner Data Bank (NPDB) to determine
whether a physician was reported to this data bank because of
involvement in VA or non-VA paid medical malpractice claims,
display of professional incompetence, or engagement in
professional misconduct.
Of the privileging requirements in VA's credentialing and privileging
policy, we selected four requirements that VA identifies as general
privileging requirements. In addition, we selected another privileging
requirement about the use of individual performance information because of
its importance in the renewal of clinical privileges. The five VA
privileging requirements we selected were as follows:
1. verify that all state medical licenses held by physicians are
valid;
2. verify physicians' training and experience;
3. assess physicians' clinical competence and health status;
4. consider any information provided by a physician related to
medical malpractice allegations or paid claims, loss of medical
staff membership, loss or reduction of clinical privileges at a VA
or non-VA facility, or any challenges to a physician's state
medical license; and
5. use information on a physician's performance when making
decisions about whether to renew the physician's clinical
privileges.
Two of the five privileging requirements--verify all state medical
licenses and consider medical malpractice information--are also VA
credentialing requirements we reviewed.
To update our work, we reviewed VA's policies, procedures, and
correspondence related to physician privileging and interviewed VA central
office officials to determine if the recommendations we made in our May
2006 report were implemented. We updated our issued work in July 2007 and
November 2007, and we performed all of our work in accordance with
generally accepted government auditing standards.
In summary, VA has specific requirements that medical facility officials
must follow to credential and privilege physicians. VA requires its
medical facility officials to credential and privilege facility physicians
periodically so that they can continue to work at VA. We reported in May
2006 that the seven VA medical facilities we visited complied with the
four credentialing requirements we reviewed and all but one of the five
privileging requirements we reviewed. However, during our review, we found
that medical facility officials did not have all of the information they
needed on physicians involved in paid VA medical malpractice claims,
because the facilities had not submitted such information in a timely
manner to VA's office that reviews the claims information and makes a
determination about whether physicians involved in the claims delivered
substandard care to veterans. We also found during our review that VA did
not require its medical facilities to establish internal controls to help
ensure the accuracy of their privileging information. Without internal
controls VA medical facility officials did not know if they properly
renewed clinical privileges, thereby allowing physicians to practice with
expired clinical privileges. Since our 2006 review, VA reports that it has
implemented all three of our recommendations to improve VA's physician
privileging process. However, since our work in 2006 we have not visited
or examined records at facilities to determine the extent of compliance.
Background
VA operates the largest integrated health care system in the United
States, providing care to nearly 5 million veterans per year. The VA
health care system consists of hospitals, ambulatory clinics, nursing
homes, residential rehabilitation treatment programs, and readjustment
counseling centers. VA delegates decision making regarding financing,
health care service delivery, and medical facility operations to its 21
networks.
Physicians who work at VA medical facilities are required to hold at least
one current and unrestricted state medical license. Current and
unrestricted licenses are those in good standing in the states that issued
them, and licensed physicians may hold licenses from more than one state.
State medical licenses are issued by state licensing boards, which
generally establish state licensing requirements governing their licensed
practitioners.^2 To keep licenses current, physicians must renew their
licenses before they expire and meet renewal requirements established by
state licensing boards, such as continuing education. Renewal procedures
and requirements vary by state. When state licensing boards discover
violations of licensing practices, such as the abuse of prescription drugs
or the provision of substandard care that results in adverse health
effects, they may place restrictions on licenses or revoke them.
Restrictions issued by a state licensing board can limit or prohibit a
physician from practicing in that particular state. Generally, state
licensing boards maintain a database that contains information on any
restrictions or revocations of physicians' licenses.
VA's Credentialing and Privileging Processes
Credentialing Process
When physicians apply for initial appointment, they initiate the
credentialing process by completing VA's application, which includes
entering into VetPro--a Web-based credentialing system VA implemented in
March 2001--information used by VA medical facility officials in the
credentialing process. Among the credentialing information that VA
requires physicians enter into VetPro is information on all the state
medical licenses they have ever held, including any licenses they have
held that have expired. For their reappointments, physicians must update
this credentialing information in VetPro.
^2State licenses are issued by offices in states, territories, or the
District of Columbia, collectively referred to as state licensing boards.
Once physicians enter their credentialing information into VetPro, a
facility's medical staff specialist--an employee who is responsible for
obtaining and verifying the information used in the credentialing and
privileging processes--performs a data check on the information to be sure
that all required information has been entered. In general, the medical
staff specialist at each VA medical facility manages the accuracy of
VetPro's credentialing data. The medical staff specialist verifies, with
the original source of the information, the accuracy of the credentialing
information entered by the physicians. This type of check is known as
primary source verification. For example, the medical staff specialist
contacts state licensing boards in order to verify that physicians' state
medical licenses are valid and unrestricted.
At initial appointment only, VA requires medical staff specialists to
query FSMB, which contains information from state licensing boards. This
query enables officials to determine all the state medical licenses a
physician has ever held, including those not disclosed by a physician to
VA, and whether a physician has had any disciplinary actions taken against
these licenses. VA does not require this query at reappointment because VA
headquarters regularly receives reports from FSMB on any VA physician
whose name appears on FSMB's list, indicating that disciplinary action has
been taken against the physician's state medical license. When VA
headquarters receives a report from FSMB, it notifies the appropriate VA
medical facility.
VA's credentialing process requires VA medical staff specialists to verify
medical malpractice claims at initial appointment and at reappointment.
These claims may be verified by contacting a court of jurisdiction or the
insurance company involved in the medical malpractice claims, or by
obtaining a statement of claims status from the attorney representing the
physician in the medical malpractice claim. In addition, VA requires
medical staff specialists to query NPDB, which contains reports by state
licensing boards, hospitals, and other health care entities on
unprofessional behavior on the part of physicians or adverse actions taken
against them. This query enables officials to determine whether physicians
fully disclosed to VA any involvement they might have had in paid medical
malpractice claims.^3 Once a physician's credentialing information has
been verified, the medical staff specialist sends the information to the
physician's supervisor, who is known as a clinical service chief.^4 The
clinical service chief reviews this information along with the physician's
privileging information. Figure 1 illustrates VA's credentialing process.
^3NPDB includes information on medical malpractice claims that are paid,
but does not include information on ongoing claims.
^4Clinical services may include surgery, medicine, and radiology.
Figure 1: Steps Taken in VA's Physician Credentialing Process
Privileging Process
Physicians, in addition to entering credentialing information into VetPro,
must complete a written request for clinical privileges. The facility
medical staff specialist provides a physician's clinical service chief
with the physician's requested clinical privileges and information needed
to complete the privileging process, including information that indicates
that the credentialing information entered by the physician into VetPro
has been verified with the appropriate sources. For reappointment,
documentation is required by another physician stating that the physician
is able to perform both physically and mentally the clinical privileges
requested. In addition, the medical staff specialist provides the clinical
service chief with information on medical malpractice allegations or paid
claims, loss of medical staff membership, loss or reduction of clinical
privileges, or any challenges to the physician's state medical licenses.
The requested clinical privileges are reviewed by a clinical service
chief, who recommends whether a physician should be appointed or
reappointed to the facility's medical staff and which clinical privileges
should be granted. When deciding to recommend clinical privileges, a
clinical service chief considers whether the physician has the appropriate
professional credentials, training, and work experience to perform the
privileges requested. For reappointment only, a clinical service chief is
to consider observations of the physician's delivery of health care to
veterans, and VA's policy requires that information on a physician's
performance, such as a physician's surgical complication rate, be used
when deciding whether to renew a physician's clinical privileges. Based on
the clinical service chief's observations and the physician's performance
information, the clinical service chief recommends that clinical
privileges previously granted by the facility remain the same, be reduced,
or be revoked, and whether newly requested privileges should be added.^5
Clinical service chiefs forward their recommendations and the reasons for
the recommendations to the next level of a medical facility's privileging
review process, which may be a professional standards board or a medical
executive committee.^6 A medical facility professional standards board or
the medical executive committee reviews the recommendations of the
clinical service chief and recommends to the facility director whether the
physician should be appointed to the facility's medical staff and which
clinical privileges should be granted to the physician. The 2-year time
period for renewal of clinical privileges and reappointment to the medical
staff begins on the date that the privileges are approved by the medical
facility's director. The list of approved clinical privileges with the
date of approval is maintained at VA medical facilities and the initial
appointment or reappointment date is entered into VetPro. Figure 2
illustrates VA's privileging process.
^5Reduction of privileges may include restricting or prohibiting a
physician from performing certain procedures or prescribing certain
medicines. Revocation of privileges refers to the permanent loss of all
clinical privileges at that facility.
^6At some VA medical facilities, the professional standards board and the
medical executive committee represent the medical staff, have the same
members, and perform the same functions so are considered to be one
committee. If the committees are separate, the professional standards
board generally consists of three to five physician peers and the medical
executive committee generally consists of all facility clinical service
chiefs.
Figure 2: Steps Taken in VA's Physician Privileging Process
According to VA's policy and a VA memorandum, information concerning
individual physician performance that is used as part of the privileging
process to either reduce, revoke, or support^7 granting clinical
privileges must be collected separately from a medical facility's quality
assurance program.^8 VA's policy is based on a federal law that restricts
the disclosure of documents produced in the course of VA's quality
assurance program.^9 In general, documents created in connection with such
a program are confidential and may not be disclosed except in limited
circumstances.^10 Individuals who willfully disclose documents that they
know are protected quality assurance documents are subject to fines up to
$20,000. Although the law states that it is not intended to limit the use
of documents within VA, VA's policy expressly prohibits the use of such
documents in connection with the privileging process. VA's use of separate
information sources for quality assurance and privileging decisions is
intended to maintain the confidential status of documents produced in
connection with quality assurance programs. According to VA, the
confidentiality of individual performance information helps ensure
provider participation, including physicians, in a medical facility's
quality assurance program by encouraging providers to openly discuss
opportunities for improvement in provider practice without fear of
punitive action.
VA has another requirement that is related to the renewal of physicians'
clinical privileges. Medical facility officials are required to submit to
VA's Office of Medical-Legal Affairs information on paid VA malpractice
claims. This information must be submitted within 60 days after the
medical facility is notified about a paid malpractice claim. The Office of
Medical-Legal Affairs is responsible for convening a panel of clinicians
to determine whether a VA facility physician involved in the claim
delivered substandard care. The Office of Medical-Legal Affairs notifies
the medical facility director of the results of its review. If it is
determined that the physician delivered substandard care to veterans, the
medical facility must report the physician to NPDB within 30 days of being
notified of the decision. VA medical facility officials also would use
this determination to decide whether to grant clinical privileges to the
physician involved in the VA medical malpractice claim.
^7Support granting clinical privileges means that the clinical privileges
previously held by the physician will be maintained and newly requested
clinical privileges will be added.
^8VA requires its medical facilities to have a quality assurance program.
In general, the VA quality assurance program consists of specified
systematic health care reviews carried out by or for VA for the purpose of
improving the quality of medical care or the utilization of health care
resources in VA facilities. See 38 C.F.R. S 17.500 (2005). These programs
collect data on various clinical process and outcome measures involving
physicians and other types of practitioners. The measures may include a
surgeon's complication rate or a physician's prescribing of medications.
Medical facility officials use these measures to look for undesirable
patterns and trends in performance.
^938 U.S.C. S 5705 (2000).
^10See Department of Veterans Affairs, VHA Handbook, 1100.19 (Washington,
D.C.: Mar. 6, 2001).
VA Has Addressed All GAO Physician Privileging Recommendations, but Extent of
Medical Facility Compliance Is Unknown
In our 2006 report, we found that the physician files at the seven
facilities we visited demonstrated compliance with four VA credentialing
and four privileging requirements we reviewed.^11 However, we found that
there were problems complying with a fifth privileging requirement--to use
information on a physician's performance in making privileging decisions.
We also found during our review that three of the seven medical facilities
we visited did not submit to VA's Office of Medical-Legal Affairs
information on paid VA medical malpractice claims within 60 days after
being notified that a claim was paid, as required by VA policy. Further,
VA had not required its medical facilities to establish internal controls
to help ensure that privileging information managed by medical staff
specialists is accurate. Internal controls are important because at one
facility we visited we found 106 physicians whose privileging process had
not been completed by facility officials for at least 2 years because of
inaccurate information. As a result, these physicians were practicing at
the facility with expired clinical privileges. None of the VA medical
facilities we visited for our 2006 report had internal controls in place
that would prevent a similar situation from occurring. To better ensure
that VA physicians are qualified to deliver care safely to veterans, we
recommended that VA
o provide guidance to medical facilities on how to collect
individual physician performance information in accordance with
VA's credentialing and privileging policy to use in medical
facilities' privileging process,
o enforce the requirement that medical facilities submit
information on paid VA medical malpractice claims to VA's Office
of Medical-Legal Affairs within 60 days after being notified that
the claim is paid, and
o instruct medical facilities to establish internal controls to
ensure the accuracy of their privileging information.
^11Findings for the credentialing and privileging requirements cannot be
generalized to the facility being reviewed because of the sample size.
VA states that it has implemented all three recommendations we
made in our May 2006 report to address compliance with VA's
physician privileging requirements by establishing policy and
guidance for its medical facilities. However, we do not know the
extent of compliance with these requirements at VA medical
facilities.
VA implemented our recommendation that VA provide guidance to VA
medical facilities on how to appropriately collect information on
individual physician performance and use that information in VA's
privileging process. Physician performance information is to be
used to assist VA medical facility clinical service chiefs in
determining the appropriate clinical privileges that should be
granted based on a physician's clinical competence. VA implemented
our recommendation by issuing a policy on October 2, 2007, that
elaborated on the sources of physician performance information and
the types of information that could be collected outside of VA
medical facilities' quality assurance programs. In addition, in
July 2007, VA officials told us that they were in the process of
implementing online training programs on physician performance
information to help implement our recommendation. The training
will be mandatory for all VA medical facility clinical service
chiefs and medical staff leaders responsible for the assessment
and oversight of the privileging process and must be completed by
January 31, 2008.
VA also implemented our recommendation that it enforce its
requirement that VA medical facilities report information on any
paid VA malpractice claims involving their physicians to VA's
Office of Medical-Legal Affairs within 60 days after being
notified of a paid claim. In June 2006, VA's Office of
Medical-Legal Affairs began notifying network and VA medical
facility directors of delinquencies in reporting this information
by the medical facilities. If a medical facility's delinquency in
reporting extends longer than 90 days, VA requires the Office of
Medical-Legal Affairs to inform not only network and VA medical
facility directors but also VA's central office of the
delinquency. Because VA's Office of Medical-Legal Affairs reviews
information on paid malpractice claims involving VA physicians to
determine whether the physicians delivered substandard care, when
VA medical facilities do not submit relevant malpractice claim
information to this office, medical facility clinical service
chiefs may make privileging decisions without complete information
about substandard care provided by physicians.
Further, VA implemented our recommendation that it instruct VA
medical facilities to establish internal controls to ensure the
accuracy of their privileging information. Internal controls help
ensure that VA medical facility officials have accurate clinical
privileging information and that physicians are not practicing at
the facility with expired clinical privileges. To address our
recommendation, VA first asked network directors to report on how
they tracked the privileging status of VA physicians. In response
to a VA memorandum sent on May 16, 2006, network directors
provided a report indicating that their medical facilities had one
or more mechanisms in place to identify physicians who were
currently privileged at their facilities and to track whether
their privileges have expired. In addition, VA instructed its
network directors to monitor the internal controls at their
facilities that ensure that VA medical facilities have accurate
clinical privileging information and that physicians are not
practicing with expired clinical privileges.
Mr. Chairman, this concludes my prepared remarks. I will be
pleased to answer any questions you or other members of the
committee may have.
Contacts and Acknowledgments
For further information regarding this testimony, please contact
Randall B. Williamson at (202) 512-7114 or [17][email protected]
. Contact points for our Offices of Congressional Relations and
Public Affairs may be found on the last page of this testimony.
Marcia Mann, Assistant Director; Mary Ann Curran; Christina
Enders; Krister Friday; Lori Fritz; Rebecca Hendrickson; and Jason
Vassilicos also contributed to this statement.
(290680)
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copyright holder may be necessary if you wish to reproduce this material
separately.
To view the full product, including the scope
and methodology, click on [18]GAO-08-271T .
For more information, contact Randall B. Williamson at (202) 512-7114 or
[email protected].
Highlights of [19]GAO-08-271T , a testimony before the Committee on
Veterans' Affairs, U.S. Senate
November 6, 2007
VA HEALTH CARE
Improvements Made in Physician Privileging Policies, but Medical Facility
Compliance Has Not Been Assessed
In a report issued in May 2006, GAO examined compliance with the
Department of Veterans Affairs' (VA) physician credentialing and
privileging requirements at seven VA medical facilities GAO visited. VA's
credentialing process is used to determine whether a physician's
professional credentials, such as licensure, are valid and meet VA's
requirements for employment. VA's privileging process is used to determine
which health care services or clinical privileges, such as surgical
procedures, a VA physician is qualified to provide to veterans without
supervision. Although GAO cannot generalize from its findings, GAO found
that the seven facilities were complying with credentialing requirements.
However, the facilities were not complying with aspects of certain
privileging requirements. To better ensure that VA physicians are
qualified to deliver care safely to veterans, GAO made three
recommendations to improve VA's privileging of physicians. GAO was asked
to testify today on (1) how VA credentials and privileges physicians
working in its medical facilities and (2) the extent to which VA has
implemented the three recommendations made in GAO's May 2006 report that
address VA's privileging requirements. To update its issued work, GAO
reviewed VA's policies, procedures, and correspondence related to
physician privileging and interviewed VA central office officials to
determine if the recommendations made in GAO's May 2006 report were
implemented.
VA has specific requirements that medical facility officials must follow
to credential and privilege physicians. VA requires its medical facility
officials to credential and privilege facility physicians periodically so
that they can continue to work at VA. Facility officials verify the
information used in the credentialing process and query certain databases
that contain information on disciplinary actions that have been taken
against a physician's state medical license and have information about a
physician's professional competence. Each physician also must complete a
written request for clinical privileges that is reviewed by the
physician's supervisor who considers whether the physician has the
appropriate professional credentials, training, and work experience. In
addition, every 2 years, the supervisor is to consider information on a
physician's performance, such as a physician's surgical complication rate,
when deciding whether to renew a physician's clinical privileges.
In a May 2006, GAO examined compliance with VA's physician credentialing
and privileging requirements at seven VA medical facilities it visited and
made three recommendations designed to improve aspects of privileging and
oversight of the process. The three recommendations were to
o provide guidance to medical facilities on how to collect
individual physician performance information in accordance with
VA's credentialing and privileging policy to use in medical
facilities' privileging process,
o enforce the requirement that medical facilities submit
information on paid VA medical malpractice claims to VA within 60
days after being notified that the claim is paid, and
o instruct medical facilities to establish internal controls to
ensure the accuracy of their privileging information.
VA reports that it has implemented all three recommendations by
establishing policy and guidance for its medical facilities. However, GAO
does not know the extent of compliance with these requirements at VA
medical facilities.
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References
Visible links
15. http://www.gao.gov/cgi-bin/getrpt?GAO-06-648
16. http://www.gao.gov/cgi-bin/getrpt?GAO-06-760T
17. mailto:[email protected]
18. http://www.gao.gov/cgi-bin/getrpt?GAO-08-271T
19. http://www.gao.gov/cgi-bin/getrpt?GAO-08-271T
20. http://www.gao.gov/
21. http://www.gao.gov/
22. http://www.gao.gov/fraudnet/fraudnet.htm
23. mailto:[email protected]
24. mailto:[email protected]
25. mailto:[email protected]
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