Certifications

Core 6 provides:

The organization implements a policy to:
(a) Verify the current licensure and credentials of licensed or certified
personnel/consultants upon hire, and thereafter no less than every 3 years;
(b) Require staff to notify organization in a timely manner of an adverse change in
licensure or certification status; and
(c) Implement corrective action in response to adverse changes in licensure or
certification status.

Again, the first thing to note about this standard is that it is mandatory. Furthermore, every subsection of the standard is a "primary element", which means that there is no aspect of the standard that an organization can miss and still expect to gain full accreditation.

The documentation required for the standard in the application is straightforward: job descriptions and a policy and procedure that addresses all three elements of the standard. The documentation for the on-site review, on the other hand, is usually where the problems arise, if there are any. During the on-site review, the URAC reviewer will request a listing of all the members of the staff (at least those that are the subject of the review), randomly select several of the staff members, and ask to see their personnel files. The reviewer will be checking the job description and resume of each of the selected employees to see if the employees meet the requirements of the job as described in the job description. In addition, the reviewer will be looking for evidence that the employee's required licenses and certifications have been verified. Therefore, a best practice is for the organization to conduct periodic audits of all of its clinical staff members' personnel files to make sure that this is happening on ongoing basis, and particularly before the reviewer arrives.

It is important to note that the scope of the standard is broad: "licensed or certified personnel/consultants". While these are not defined terms, it is fairly clear that the URAC standard would sweep up a pretty broad array of licensed and certified people, not just employees.

One thing to note is that the standard applies not only to licensure, but also to certification. This is particularly important with respect to accreditation standards such as case management, where certification might be a requirement. Be sure, therefore, that your process of verification, both as described in your policy and procedure and in practice, includes all certifications that might be required by the particular accreditation standards under which you are applying or by your own policies and procedures.

Finally, make sure not only that your policy and procedure on the subject imposes an affirmative obligation on the licensed personnel and consultants to notify the organization of adverse changes in licensure or certification status, but that everybody has been trained on this obligation. It would not be a good thing in an interview with a member of your staff if it became apparent that this requirement was unknown to licensed or certified staff members.