Completing the Important Practice Paperwork
by Patrick C. Alguire, MD, FACP
Director, Education and Career Development, ACP
For a smooth transition from residency or fellowship training to practice, you must pay attention to the paperwork. The paperwork must be completed in a timely fashion, and be meticulously complete in order to avoid delays in beginning your clinical practice. The purpose of this article is to review what paperwork needs to be completed, and how best to go about it.
First, make sure that your medical license is in order. If the license application was completed during the training period, and you are remaining in-state, nothing more needs to be done other than informing the licensing board of your new practice address. However, if you never obtained an unrestricted license, or will be moving out of state, this application needs to be attended to promptly. The medical license application process may take between 4 to 6 months. Applications can be obtained by writing or calling the state licensing agency. The state medical boards can be accessed here.
Although state licensing board requirements vary, they generally request the same types of core information including; a notarized personal photograph of the applicant, medical school transcripts, a copy of the medical diploma, USMLE scores, documentation of postgraduate training, specialty certification (if available), and a report from the National Practitioner Data Bank. The NPDB (http://www.npdb-hipdb.com/) is a repository of adverse actions taken against physicians including malpractice claims or settlements, state medical board sanctions, convictions for fraud or abuse, and other similar data.
Many state medical boards also request your curriculum vitae. It is important that the dates on your curriculum vitae correspond exactly to the dates from the various institutions documenting your training, and that there be no unexplained gaps of time. For example, my medical license from the state of Florida was delayed because I failed to account for the time between medical school graduation (May) and beginning my residency (July). Informing the medical board that I was on vacation met their needs, but the time gap in my CV delayed my license application for several weeks.
The medical license application will be very specific as to how the required information should be accessed, and how it should be transmitted to the licensing agency. Failure to follow the application instructions precisely will result in long and costly delays. It is advisable when beginning the application process to create an organizational chart that details what information you have requested, when it was requested, to whom the request was sent (name, address and telephone number), and a notation of any processing fee that was sent (check number and date). Your requests for documentation from the various organizations must be made in writing, and you should always make a copy of your correspondence for future reference.
It is not unusual to discover that your application has been delayed because an institution (a medical school, for example) did not forward the needed information to the licensing agency as requested. It is your responsibility, not the responsibility of the licensing agency, to contact the wayward institution and follow up on the missing documentation. When making calls to the institution, always take down the full name and title of the person helping you, and put that information on you organizational chart for future reference. Finally, it is a good idea to contact the licensing agency periodically, every 6 weeks for example, to check on the progress of your application. Do not rely on the licensing agency to inform you of missing or incomplete information.
As a service to physicians, the Federation of State Medical Boards offers a Federation Credentials Verification Service (FCVS) to provide a centralized, uniform process for state medical boards to obtain a verified, primary source record of a physician's core medical credentials. This service is designed to lighten the workload of credentialing staff and reduce duplication of effort by gathering, verifying and permanently storing the physician's and/or physician assistant's credentials in a central repository at the FSMB's offices. FCVS obtains primary source verification of medical education, postgraduate training, examination history, board action history, board certification and identity. This repository of information allows a physician and/or physician assistant to establish a confidential, lifetime professional portfolio with FCVS which can be forwarded, at the physician's request, to any state medical board that has established an agreement with FCVS, hospital, health care or any other entity. The base fee is $295, with an additional $50 fee for physician applications not submitted online. The subsequent Profile (any profile sent subsequent to your initial profile) carries a significantly lesser cost, with a base fee of $90, with an additional $25 fee for physician applications not submitted online. Additional profiles (the physician's profile sent to additional state medical boards, hospitals or health care entities at the same time as an Initial or Subsequent profile) are available for $60 each plus any additional surcharges.
Despite the expense, there are several potential advantages to the FCVS. The first advantage is avoiding the time and hassle of completing the licensing process on your own. Second, FCVS shortens the processing time, as compared to what you can accomplish on your own. Third, it has been estimated that physicians must produce documentation of their medical credentials over 50 times during an average career; once FCVS has completed the initial application process, it maintains a permanent record of all your primary documents for future use. Finally, this process may be particularly cost effective for physicians graduating from medical schools outside of the United States, where verification is often time consuming and difficult.
In addition to the medical license, new physicians must apply for hospital privileges through the hospital's medical staff office, a process that can easily take 4 to 6 months. The types of credentials usually requested by the medical staff office are similar, if not the same, as required by most state licensing agencies. In addition, it is not unusual for the medical staff office to request an interview prior to granting privileges. If you are moving to another city, it might be worthwhile to complete the interview during one of your regularly scheduled trips to your new location, rather than making a separate trip for this interview.
Other important paper work includes obtaining your insurance provider numbers. In order to be paid by third party insurance carriers, you must have a provider number for each insurance company and managed care organization with which you wish to participate. If you are joining another physician or group, chances are the office staff will obtain these numbers for you. If you have previously moonlighted, you may already have your Medicare provider number; this federal identification number never changes once it is assigned to you. As of May 23, 2008, the National Provider Identifier (NPI) is required for all HIPAA Standard Transactions. The NPI is a 10-position, intelligence-free numeric identifier (10-digit number). This means that the numbers do not carry other information about healthcare providers, such as the state in which they live or their medical specialty. Your NPI can be obtained at no cost.
Physicians who prescribe controlled substances will need a Drug Enforcement Agency (DEA) Controlled Substance Registration Certificate. An application can be obtained by calling 1-800-882-9539. Some states also require a State Controlled Substance License. This application is usually part of the state medical license application.
If you are beginning your own practice, you may require a Federal Employee Identification Number (FEIN). The FEIN is required of any business that takes tax and other payroll deductions from the salary of one or more employees, and is obtained by filling out IRS form SS-4. A different number is required for each unique site of business. If joining a group or organization, you will not need to obtain a FEIN, since it is site specific, not person specific. Many states and cities also mandate a State Employee Identification Number, and this is usually obtained from the respective departments of treasury. Like the FEIN, the state number is business, not person specific.
The Health Care Financing Agency regulates all laboratory testing through the Clinical Laboratory Improvement Amendments (CLIA) program. For offices that perform even minor laboratory tests, a CLIA certificate is required. If starting a practice, you must apply for certification; if joining a practice or organization, the certification will already be in place. Like the FEIN, the CLIA certification is site, not person, specific.
In summary, completing the paperwork for the transition into practice is a time consuming, occasionally frustrating, but essential task. The most common mistake is under estimating the time necessary to complete the task. Start now, and be compulsive.
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