When a health tourism coordinator represents that their provider network selection process involves due diligence but doesn’t conduct primary source verification of credentials, training and experience, I view that as false advertising which is illegal in most jurisdictions.
Professional health and wellness services coordinators and facilitators owe a duty of due diligence to clients
Without one of these two procedures in place and followed meticulously, I call them a greedy “hack” appointment setter working solely for advertising commissions, with reckless disregard for their client’s safety.
The Importance of Healthcare Provider Credentialing in Health Tourism
When a doctor or nurse has a mask on their face, they essentially all look alike: The ones who graduated with an “A” in medical school, the ones who barely graduated, and those who may never have attended or graduated medical school. Many patients know very little about their doctor’s qualifications beyond the diplomas and certificates hanging from the clinic office wall. There’s often a virtual safety net that exists because the other doctors, nurses and hospital executives and administrators know and work with that doctor locally act as a sort of check and balance. But when a patient travels far away from home, how do they know if the credentials, experience and training of the doctor or the physiotherapist or the massage therapist working at the hotel spa are real?
As a professional health and wellness tourism services coordinator, part of your professional services fee is meant to cover the vetting and preparation you’ve done to improve your client’s chances of being treated by genuinely qualified healthcare professionals. For Mercury Healthcare International, and its Mercury Health Travel Approved Provider Network, this was the most labor intensive (and costly) aspect of health tourism provider network development for the world’s first and only Globally Integrated Health Delivery System®.
The term, Globally Integrated Health Delivery System® implies that a common vetting and privileging system exists throughout the network, applied without geographic variation. We measured all credentials the same way, according to the same standards and network rules. The rationale for this was simple: All doctors, nurses, therapists, and other allied health practitioners (and health benefit plan administrators) could trust that those privileged to be deemed Approved Providers were held to the same standards no matter where they practiced medicine, nursing or allied health services. This is the first element of brand differentiation for Mercury Health Travel.
If we did not undertake the actual vetting and primary source verification by our Medical Staff Services (MSS) team or our contracted Accredited Credentials Verification Organizations (ACVO) coupled with Mercury Health Travel’s regional medical director’s peer review, then we instead vetted how the hospital or clinic performed the vetting and reviewed their policies, procedures, and standards.
Our standards and practices didn’t simply permit us to accept their paperwork as bona fide proof that the system was followed. We spot checked several files similar to the tracer methodology used by many accrediting bodies who were, themselves, internationally-accredited. When this process is outsourced to the hospital, the procedure and practice is called delegated credentialing.
In the United States, there are businesses who do this work for hire. They seek accreditation for their processes by the National Committee for Quality Assurance (NCQA), and are then designated as Accredited Credentials Verification Organizations (ACVOs). To act as an ACVO and represent that certain policies and practices are meticulously followed in all instances carries with it professional liability due to the risk of negligence. To date, we have not identified ACVOs operating outside the USA. I believe that this is one reason there are not so many carriers that will underwrite a medical tourism facilitator’s professional risk insurance – because most facilitators, certified or non-certified have not implemented a published workflow and procedural standards for physician, dentist, and allied health practitioner credentialing and privileging at this level, so the risk to the professional liability insurer is high.
Provider credentials verification is single most important thing consumers should expect from businesses that offer medical or dental tourism referral coordination.
Healthcare provider credentialing and privileging (allowing one to perform certain procedures after demonstrating adequate competency by peer review or volumes of procedures and verified references for training of continuing medical education) is important because it is the single process that allows patients to confidently place their trust in their chosen healthcare providers and providers to trust the qualifications and experience of physicians involved in case management and treatment of the patient outside their local community. The standardized process involving data collection, primary source verification and committee review by health plans and insurers, hospitals and clinics, health and wellness tourism services coordinators or facilitators and other healthcare agencies, gives patients assurances of the quality and safety of healthcare professional’s training, credentials, and experience.
Of the 85,000 physicians we had in the Approved Provider network, roughly 65,000 of them were based in the USA and had been recently credentialed or re-credentialed by the ACVO. The remaining 20,000 were scattered across 115 countries on 5 continents.
When I evaluate a health and wellness tourism services coordinator or facilitator for professionalism, I look for two things:
- that they have established a process to evaluate the health facilities they plan to work with to verify and prove (through the tracer methodology) that adequate primary source verification (PSV) and core privileging was performed to their satisfaction; or
- that they have internally performed the PSV and established their standards (aligned with the best of the accrediting bodies standards and procedures).
Without one of these two procedures in place and followed meticulously, I cannot call them a professional health and wellness tourism services coordinator or facilitator; I call them a greedy “hack” appointment setter working solely to be paid advertising commissions, with reckless disregard for their client’s safety.
Why? Because the health and wellness tourism services coordinator or facilitator is representing and warranting to the client that they selected a network of providers and put them through some screening process before allowing the patient to choose them from the facilitator’s “short list” of qualified providers.
Without this process in place, I don’t believe that due diligence can be asserted. The facilitator is merely acting as a commissioned advertising agent of the hospital or physician or clinic and merely impanels providers who have agreed to pay the facilitator or agency a negotiated fee for the value of the referral stream and appointment setting. In the USA, payment for referrals violates the Federal Anti-kickback Statute (FAS).
If the health and wellness tourism services coordinator or facilitator represents to the public that it has performed due diligence, a reasonable person would expect some screening and verification process to be implemented and followed. To represent otherwise is to intentionally (“fraud”) or blatantly (“to perform with willful ignorance of professionally accepted practices”) misrepresents to customers that the selection process involves a due diligence selection criteria. That, to me, is false advertising which is illegal in most jurisdictions. After all, isn’t that one of the things they assume they are paying for? Therefore, when a health and wellness tourism services coordinator or facilitator represents that it qualifies healthcare providers through fam tours and site inspections but skips over this costly and labor intensive process, I view it as immoral and a misrepresentation of the value of their services to an otherwise vulnerable client who most likely has no way to otherwise short list qualified medical and dental providers. It is tantamount to patient endangerment. If health and wellness tourism services coordinator or facilitator sidesteps this responsibility and duty of due diligence by placing a disclaimer of liability in their Client Agreement, that raises my disdain for their professionalism even higher.
Using a disclaimer of liability in their contract does not exonerate them of their professional duty of due diligence. In my opinion, it exacerbates the fraudulent misrepresentation in the advertised value of their services. The reason I am so critical of this is because I know how difficult it is to get the hospitals and other credentials granting institutions (medical schools, residency programs, certification boards, licensing authorities, etc.) to agree to cooperate and follow through. But simply because it is costly and labor intensive and requires training and professional development (and optional professional skills certification by the National Association of Medical Staff Services (NAMSS) does not give them an excuse not to do it.
About the Author:
Maria Todd is a healthcare industry entrepreneur, best selling author, philanthropist, and the US’s number one medical tourism business strategist. Need proof? Google her name and “medical tourism” and decide for yourself. The author of 5 internationally best-selling books on medical tourism business development, Maria has empowered hundreds of doctors, nurses, tour operators, destination managers, travel agents and others from a hundred countries. Through her audio, video, live seminars and professional Master Classes she’s helped them to become professional managers and coordinators of health & wellness tourism services.
Maria Todd has been helping people in health and wellness tourism solve complicated problems for more than 30 years. She’s helped healthcare professionals improve their business. She’s helped friends, family and health tourism clients access the healthcare and travel services they need to improve or extend their life. She teaches others interested in the business of health tourism the chance to do the same through a customized, self-paced training program.
She shares practical tools, tips and techniques cultivated over 30+ years in the business of health and wellness tourism at both the consumer and corporate level through her blogs on LinkedIn, and here at the Center for Health Tourism Strategy.
Maria has professional work experience as a travel agent and tour operator, advanced degrees in Health Administration, training and work experience as a surgical nurse, and has worked as a health law paralegal and HMO Contract Manager. She has negotiated insurance contracts for doctors, dentists, hospitals and other healthcare providers from the payer and provider side since 1983. As a consultant, she has helped more than 20 healthcare organizations prepare for international and US accreditation and managed hospitals, clinics and same-day surgery facilities. She organized and worked as the CEO of the world’s first and only Globally Integrated Health Delivery System®, and awarded a registered trademark for this new term of art by the USPTO in 2010. She built the world’s largest medical tourism network of Approved Providers that included more than 6000 hospitals and clinics and over 850,000 physicians, dentists and other practitioners in 115 countries. Her proprietary standards for health and wellness tourism business are implemented at hospitals, employers, insurers, and government authorities around the world. She won a direct appointment contract to develop the national medical tourism strategy for Greece in 2014 after being vetted by American Embassy officials in Athens. You owe it to your business and your professional brand to learn best practices for health and wellness tourism services coordination from her, and with these choices below, there’s no reason not to do so, starting today.
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