Telemedicine credentialing by proxy is conditional reliance on distant-site credentialing and privileging decisions under 42 CFR 482.22 for hospitals and 42 CFR 485.616(c) for critical access hospitals (CAHs). Integral Healthcare Solutions (IHS) drafts checklists, privileging procedures, review logs and bylaws language for organizations considering or using this option; counsel drafts and approves contracts. Neither section uses the phrase “credentialing by proxy.”
Last updated: November 2026
What do 42 CFR 482.22 and 485.616 require for telemedicine credentialing by proxy?
Sources: current eCFR, 42 CFR 482.22, Medical staff, 42 CFR 482.12, Governing body, and 42 CFR 485.616, Agreements; page opened November 5, 2026 via GPO's eCFR XML, built November 4, 2026. Title 42's recorded last amendment is October 8, 2026.
Under 482.22(a)(3) through (4), when telemedicine services are furnished through an agreement with a distant-site hospital or entity, the receiving hospital's governing body may authorize its medical staff to rely on that site's credentialing and privileging decisions when recommending privileges for individual practitioners. This replaces the requirements of (a)(1) through (2) only if the governing body ensures all applicable provisions through its written agreement. The receiving hospital's governing body grants privileges under 482.12(a)(8) through (9); the entity provision addresses physicians and practitioners employed by that entity.
For CAHs, 485.616(c)(2) and (4) let the governing body or responsible individual choose reliance on the distant-site governing body's decisions about individual practitioners, with the listed provisions ensured through a written agreement.
Agreement elements, side by side
| Element | Distant-site hospital | Distant-site telemedicine entity |
|---|---|---|
| Standing | Must be Medicare-participating. | Its medical staff credentialing and privileging process and standards must at least meet 482.12(a)(1) through (7) and 482.22(a)(1) through (2) for hospitals, or 485.616(c)(1)(i) through (vii) for CAHs. |
| Privileges | Each practitioner is privileged at the distant site, which supplies a current list of that practitioner's privileges. | |
| License | Each practitioner holds a license issued or recognized by the State where the receiving hospital or CAH is located. | |
| Feedback | For practitioners holding current privileges at the receiving facility, it keeps evidence of internal review of performance of those privileges and sends performance information to the distant site for periodic appraisal. At minimum, information includes all adverse events resulting from their telemedicine services to its patients and all complaints it has received about them. | |
What must the agreement assign?
For a distant-site hospital, 482.12(a)(8) and 485.616(c)(1) require the written agreement to assign its governing body responsibility for the listed duties concerning its telemedicine practitioners: determine eligible practitioner categories under State law; appoint staff after considering existing staff recommendations; ensure and approve bylaws and approve other staff rules; ensure staff accountability for care quality; use character, competence, training, experience and judgment as selection criteria; and never base staff membership or privileges solely on specialty-body certification, fellowship or membership.
For an entity, the written agreement must identify it as a contractor and require services permitting compliance with all applicable conditions of participation for the contracted services. Hospital provisions are 482.12(a)(9), including (a)(1) through (7), and 482.22(a)(4), in accordance with 482.12(e). CAH provision 485.616(c)(3) includes that section's practitioner requirements and references 485.635(c)(4)(ii).
What do the bylaws have to say?
Under 482.22(c)(6), hospital bylaws include privileging criteria and procedures for applying them. For distant-site practitioners requesting telemedicine privileges under an agreement, these are also subject to 482.12(a)(8) through (9) and 482.22(a)(3) through (4).
Who needs it and what triggers it?
This service is for hospitals and CAHs considering or reviewing reliance on a distant site's credentialing and privileging decisions. Reliance is optional; purchasing outside telemedicine coverage does not itself require buying this consulting service.
- Before choosing reliance, review the written agreement against 482.22(a)(3) through (4) or 485.616(c).
- When reviewing hospital bylaws, check distant-site privileging criteria and procedures against 482.22(c)(6).
How IHS helps
IHS assesses gaps against these provisions, maps documents and evidence, drafts procedures and clinical content for your clinicians to approve, conducts a mock review and supports readiness. Thomas G. Goddard, JD, PhD, IHS founder and former URAC Chief Operating Officer and General Counsel, leads the work. IHS runs three practice lines, Accreditation Consulting, Compliance Services and Program Development, and this build sits in Program Development, alongside compliance program development and Compliance Services.
What IHS drafts
- An agreement element checklist for counsel, with one column for a distant-site hospital and one for an entity.
- A privileging procedure for distant-site practitioners.
- A periodic review log of the adverse events and complaints sent back to the distant site.
- Bylaws language for distant-site privileges.
- A mock review of sample practitioner files.
What you supply
You supply the telemedicine agreements, the governing body's decision to rely or not, the distant site's privilege lists and licenses, and your own adverse event and complaint data.
The real limit
The agreement language is legal drafting, so counsel writes and approves it. IHS does not decide clinical content, does not draft contracts as counsel and does not guarantee a survey outcome.
What to have ready
Use the current eCFR provisions opened November 5, 2026. Gather the following for the applicable hospital or CAH route.
- Written agreements assigning distant-site hospital governing-body duties or entity contractor obligations (42 CFR 482.12(a)(8) through (9); 42 CFR 485.616(c)(1), (3)).
- Evidence of the distant-site hospital's Medicare participation (42 CFR 482.22(a)(3)(i); 42 CFR 485.616(c)(2)(i)).
- For an entity, evidence its medical staff credentialing and privileging process and standards at least meet the applicable hospital or CAH standards (42 CFR 482.22(a)(4)(i); 42 CFR 485.616(c)(4)(i)).
- Current lists of each practitioner's distant-site privileges (42 CFR 482.22(a)(3)(ii), (4)(ii); 42 CFR 485.616(c)(2)(ii), (4)(ii)).
- Licenses issued or recognized by the receiving facility's State (42 CFR 482.22(a)(3)(iii), (4)(iii); 42 CFR 485.616(c)(2)(iii), (4)(iii)).
- For practitioners currently privileged at your facility, evidence of internal review of performance of those privileges and information sent for distant-site periodic appraisal, including all resulting telemedicine adverse events and all complaints received about them (42 CFR 482.22(a)(3)(iv), (4)(iv); 42 CFR 485.616(c)(2)(iv), (4)(iv)).
- Hospital bylaws with privileging criteria and procedures (42 CFR 482.22(c)(6)).
- Your record of the decision on reliance; IHS requests it for planning, without treating a separate resolution as a requirement of 42 CFR 482.22(a)(3) through (4) or 42 CFR 485.616(c)(2), (4).
Bring this checklist to the free introductory call to discuss scope.
How it compares
A hospital has three ways to credential distant-site practitioners. IHS names them without ranking them.
| Route | What the text says | Note |
|---|---|---|
| The hospital credentials and privileges the practitioner itself | 482.22(a)(1) through (2): periodic staff appraisals, credentials examination and appointment recommendations under State law, including scope-of-practice law, and staff bylaws, rules and regulations; appointed candidates remain subject to those rules and this section. | The reliance options are offered in lieu of these. |
| Rely on a distant-site hospital | Paragraph (a)(3), under a written agreement with the listed provisions. | CAHs have the parallel route in 485.616(c)(2). |
| Rely on a distant-site telemedicine entity | Paragraph (a)(4), under a written agreement with the listed provisions. | CAHs have the parallel route in 485.616(c)(4). |
For the staff bylaws that hold the privileging criteria, see hospital medical staff bylaws and credentialing build, and for general program design see credentialing program design.
What it costs
Neither 42 CFR 482.22 nor 485.616 states an application fee or other authority fee.
The cost of this build depends on how many distant-site agreements you have, whether you are a hospital or a CAH, how many practitioners are covered, and how much distant-site privileging language your bylaws already hold.
IHS scopes each engagement after a free introductory call.
What this is not
- IHS is a consulting firm, not a law firm; this is not legal advice or a guarantee of a survey outcome, and counsel approves agreement language.
- IHS does not contact, submit to or correspond with CMS, any state agency or the distant site for the hospital.
- This page covers the text of 42 CFR 482.22, 482.12 and 485.616 only. Accreditor proxy rules and state telemedicine law are separate subjects that this page does not cover.
Frequently asked questions
What is credentialing by proxy for telemedicine?
For hospitals, it means the governing body's optional authorization for medical staff to rely on a distant hospital's or entity's credentialing and privileging decisions when recommending individual telemedicine privileges under 42 CFR 482.22(a)(3) through (4). Reliance replaces (a)(1) through (2) only when all applicable written-agreement provisions are met; the receiving governing body grants privileges under 482.12(a)(8) through (9). Neither section calls this proxy.
Who decides whether a hospital relies on a distant site's credentialing?
The governing body of the hospital whose patients receive the telemedicine services, and only if its written agreement ensures that all of the listed provisions are met. For a CAH, the governing body or responsible individual chooses under 485.616(c)(2) or (c)(4).
What must the agreement with a distant-site hospital contain?
The written agreement must assign the distant-site hospital's governing body the duties in 482.12(a)(1) through (7), or 485.616(c)(1)(i) through (vii) for a CAH. For reliance, it must also ensure Medicare participation, distant-site privileges and current privilege lists, licenses issued or recognized by the receiving facility's State, and the performance-feedback provisions in 482.22(a)(3)(iv) or 485.616(c)(2)(iv). Those provisions cover practitioners currently privileged at the receiving facility and require internal-review evidence and performance information for distant-site periodic appraisal, including all resulting telemedicine adverse events and all complaints received about them.
What is different when the distant site is a telemedicine entity rather than a hospital?
The entity's medical staff credentialing and privileging process and standards must at least meet 482.12(a)(1) through (7) and 482.22(a)(1) through (2) for a hospital, or 485.616(c)(1)(i) through (vii) for a CAH. Under 482.12(a)(9) and 485.616(c)(3), the written agreement must identify the entity as a contractor and require services permitting compliance with all applicable conditions of participation for contracted services, including the specified practitioner requirements. The hospital provision references 482.12(e); the CAH provision references 485.635(c)(4)(ii). Reliance also requires the other listed provisions in 482.22(a)(4) or 485.616(c)(4).
What performance information goes back to the distant site?
For a practitioner who holds current privileges at the hospital, the hospital must have evidence of an internal review of performance and send that information for use in the distant site's periodic appraisal. At a minimum it includes all adverse events from the telemedicine services to the hospital's patients and all complaints the hospital has received about the practitioner.
Does the same option apply to critical access hospitals?
Yes, in 485.616(c). A CAH's governing body or responsible individual may choose to rely on a distant-site hospital's credentialing and privileging decisions under (c)(2), or an entity's under (c)(4), if its written agreement meets the listed provisions.
Do bylaws need to address distant-site practitioners?
Yes. Paragraph (c)(6) of 482.22 makes the privileging criteria and the procedure for applying them, for distant-site practitioners requesting privileges under an agreement with the hospital, also subject to 482.12(a)(8) and (a)(9) and 482.22(a)(3) and (a)(4).
What does IHS draft and what does counsel approve?
IHS drafts the checklist, privileging procedure, review log and bylaws language. Counsel approves the agreement language, the governing body decides whether to rely, and the hospital supplies the contracts, privilege lists, licenses and performance data.
Who communicates with CMS and the distant site?
The hospital and its counsel do. IHS does not contact, submit to or correspond with CMS, a state agency or the distant site for the hospital.