About Reporting Compliance
The statutes governing the NPDB require State Licensing and Certification Authorities to submit, within 30 days, adverse licensing and certification actions, as well as negative actions and findings, taken against health care entities, providers, suppliers, and practitioners. HRSA is actively engaged in compliance activities that are improving the completeness and accuracy of data reported to the Data Bank.
The first major activity was the "Never Reported Professions Compliance Effort." Starting in March 2010, HRSA developed a list of current State Agencies and Licensing and Certification Boards responsible for licensing or certifying health care professionals. The listing was compared to data reported to the NPDB and the former Healthcare Integrity and Protection Data Bank (HIPDB) to determine if these government agencies (i.e., State Licensing and Certification Boards) had reported any actions to the Data Bank. Through this analysis, HRSA determined that certain government agencies may not have reported any adverse actions on specific professions. These government agencies are included in the "Never Reported Professions Compliance Effort." Through this effort, HRSA contacted these agencies, determined the professions subject to the reporting requirements, and continues to work with agencies to ensure appropriate reporting.
The second major compliance activity was the "Adverse Licensure Action Comparison Project." In this effort, HRSA compared publicly available adverse actions published on state websites for certain years with data which had been reported to the HIPDB, and which is now stored in the NPDB. In 2010, HRSA publicly posted the compliance status for nurses, pharmacists, physician assistants, podiatrists, psychologists, and social workers. The effort was expanded in 2011 to include physicians (allopathic and osteopathic), dentists, chiropractors, optometrists, and physical therapists. In 2012, behavioral health professionals (e.g., counselors, therapists, and substance abuse providers) were added. For the states where HRSA could not find publicly available adverse actions on the website, HRSA requested that the state provide the data so that HRSA could conduct a comparison.
Our current process focuses on reviewing adverse licensure and certification actions in the Data Bank for the 12 most queried professions (i.e., nurses, pharmacists, physician assistants, podiatrists, psychologists, social workers, physicians, dentists, chiropractors, optometrists, physical therapists, and behavioral health professionals) in each state. Allied health professions (e.g., pharmacy technicians, nursing assistants, dental hygienists) are also included. Each state will be reviewed on a two year cycle.
In all situations where our review indicates that a government agency may not be compliant with the reporting requirements, HRSA contacts the agency with a request to, within 30 to 45 days: (1) Supply a written explanation stating the reason the actions were not reported or stating that the profession is not subject to the reporting requirements; (2) Report the potential missing actions taken by the government agency and provide written notice that the actions were reported; or (3) Provide a Corrective Action Plan detailing how the government agency will meet the reporting requirements.
The attestation process allows the Data Bank to account for those professions that are not the 12 most queried professions and enables entities to certify that they have submitted all required reports and are maintaining reporting compliance for the professions they regulate. This attestation will be linked to the registration renewal process. As such, each board will be reviewed on a two year cycle.
The compliance status of government agencies includes only those states and professions that HRSA has reviewed or is currently reviewing. HRSA has focused on those government agencies that report individuals (e.g., practitioners). Future compliance reviews will address additional subjects of reports.