.""'
PHYSICIANS APPLYING FOR

FEDRA 
SERV I CE :

REQUIREMTS AND CREDENTIALS VEIFICATION

\&IVrCl.. 
M. 
1o 
"'tlJa 
OFFICE OF INSPECTOR GENERAL 
OFFICE OF ANALYSIS AND INSPECTIONS 
SEPTMBER 1988  Office of Inspector General

(OIG) is to

The mission of the Office of Inspector General 
promote the efficiency, effectiveness and integrity of programs

in the United states Department of Health and Human Services

(HHS) . It does this by developing methods to detect and prevent

abuse.  1976, the 
Created by statute in 
fraud, waste and 
Inspector General keeps both the Secretary and the Congress fully 
and currently info  ed aacbtoiuotn p.r ograms or management problems and 
The eIG performs its mission by 
recommends corrective 
conducting audits, investigations and inspections with

approximately 1, 200 staff strategically located around the 
country . 
fice of Analysis and Inspections

This report is prodtuhceeed  bmy atjoher  oOffffiiccees  owf itAhnianl ytshies  OanlGd .I nTshpee cottihoenrs 

(OAl), one of the 
Investigations. 
two are the Office of Audit and the Offtiycei coafl ly short-term 
The OAl conducts inspections which are 
effectiveness, efficiency

studies designed to determine program 
abuse. 
and vulnerability to fraud or 
This study was conducted to (1) identify the education and

care 
licensure requirements for physicians in full-time clinical 
posi tions in Federal agencies: and (2) review the process 
followed to verify physician credentials.

The report was prepared under 'the direction of William C. Moran, 
Inspections, 
Regional Inspector General, Office of Analysis and 
'the following 
Region V. Participating in this project were 
people: 
Leader  Alan Levine - Headquarters 
Natalie Coen, Project 
John Traczyk

Suzane Johnon

Margaret Shell 
Aquilla Box
 PHYSICIANS APPLYING FOR

FEDER 
SERVICE: 
REQUIREENS um CREDENIALS VERIFICATION 
RICB 
P. GKUSESENRO W 
INSPECTOR 
OAI-05-88-00750  &rmGER 1988  EXCUIVE SUMY

PURPOSE  This inspection was conducted at the request of the
President' 
s Council on Integrity and Efficiency to review 
physician credentials requirements of various Federal agencies 
and to evaluate the methods used to verify physician credentials. 
The study focused on the qualifications of full-time physicians
invol ved with 
patient care. 
Federal and State Governents, 
BACKGROUN  as well as the 
private sector, have become increasingly concerned about

physicians ' performance 
and qualifications. The number of 
malpractice suits filed against Federal and private physicians

1980. 
has increased steadily since  The number of license 
revocations taken by State boards increased almost 60 percent

from 1984 to 1986. The news media has reported cases of

unethical or incompe  behavior by priva  e physicians as well 
as some of 
 he approxima ely 24,000 physicians that 
 e Office of

Personnel Managemen  by the
Federal Governen  (OPM) reports were employed in  i985 
he Federal Bureau of
Investiga  In addi  ion,
ion has iden ified a number of "diploma mills" selling
bogus medical degrees. 
The New England Journal of Medicine in a February 11, 1988
led "
Parhtyicslice iaenn   Falsification of Clinical Creden ials by
Applying for Ambula ory-S  aff Priiavillse gliess " reports on
the results of a review of clinical creden 
ed by
applican 
physicians. Of 733 physicians applying for positions,
5 percent gave false informa ion about their residency, 1.

percent falsely reported board cer ifica  ion and . 
3 percent
provided false information about bo h residency and board
certifica  ion. 
Based on information supplied by OPM
, we selected for review 7

Federal agencies with 35 or more full- ime physician on s aff
as of 1985:  the Deparent of 
( 1) 
Health and Human Services 
ration
(the Social Securi ty Adminis  , the Health Care Financing
Adminis  ion
, the Cen ers for Disease Con rol, the Alcohol Drug
Abuse and Men al Health A  nis  ion, the Food and Drug
Admni.  ion
an  h Resources and Services Administra ion
D(HeRpSaArt)e, n  the,  theN Haeal   ional InAs i rtu   es of Heal  h ) : ( 2) the
of St:a  e; ( o4f)  Dthefee nDsee p(athree nt of Tanradn thpeo rNtaatviyo)n;  (( t3h)e t he Department
Coast Guard
and the Federal Av1a ion Adminis  ion); (5) the Deparent
Justice (the Bureau of Prisons); (6) the Ve eran Admnis ration
(VA); and (7) the Na ional Aeronau ics and Space Admni.tration
(NASA). For ea.e in 
reporting, 3 agencies, (NAA, 
Depar'tent of S  e) plus the 12 COponen  s in the VrA,e anmdaining 4
agencies will hereafter be referred to as organzations.  Most of the Federal organizations reviewed in this study operate 
under a combination of two of the following personnel systems:
the civil service, the Public Health Service (PHS) Commissioned
Corps and the military services. The VA and Department of State
own. 
have personnel systems uniquely their  Each personnel system
establishes minimum physician qualification standards and uses a 
uniform application form. However, each individual organization
may require additional qualifications or information not
solici ted 
on the standard personnel forms.. 
The military, the PHS Commissioned Corps, and the VA have

recently revised their physician qualifications and verification

procedures. Many of the best practices identified in this report

reflect these changes.. The OPM is also currently revising the

standards and qualifications required of civil service

physicians.. We hope this report can further assist these

organizations in refining their credentialing processes 

FINDINGS: 
All personnel systems require physician applicants who will 
provide direct patient care to hOld, at a minimum, a
medical degree from an accredited school or to demonstrate 
comparable medical education and training if graduating from 
a foreign or unaccredited school. In addition, physicians
must have completed an approved residency program and 
unestricted 
pliocsseensss ea.  current, valid,  reqire  State medical
Five organzations 
board certification in 
specified medical specia1ty areas for certain positions.. 
Civil service is the only personnel system that does not

require clinical care physicians, once employed, to maintain

curent, valid licenses. 
Disclosure requirements vary widely. There is no uniformity
amng personnel 
organzations. systems, agencies or wi thin some
organzations 
reqire  Wi thin the 15  studied, none
disclosure of Medicare/Medicaid sanctions, only 2
voluntar surender of a 
consistently ask about'  licensee s) ,
and only 3 require information regarding censure or
staff. 
reprimad by a 
bespi tal  Three consistently request
malpractice claims information. In addition, disclosure
reqirements are frequently 
limiting or unclear, allowing an
applicant to misinterpret or withold the reqired
information. 
Few organizations, with the notable exception of the Ary,
Navy, and VA, consistently verify all physician credentials 
schools, althugh
wi th primary sources such as medical 
several organizations consistently verify .edical licenses 
State boards. 
wi th  Some respondents assumed incorrectly  tha 
he Na ional Agencyi aClhsec.k  and Inquiry constituted 
verification of creden  Some organizations are not 
a ban 
he physician disciplinary da 
ilizing  maintained by
he Federa ion of State Medical Boards  o identify
adverse practice history information (FSMB) 
, nor are they
requesting the American Medical Association s (AH)
physician profile. Only PHS, the Army, Navy and VA have
established written guidelines on proper verification

procedures. 
RECOMMENATIONS: 
Agencies employing civil service, clinical care physicians 
slhioculde renquisre es; or  hem to main ain curren , valid State medical
reqior ebe a cloln csiisv il  wi th o her personnel syste
service physician, 
OPM should  once
employed, to main ain medical licensure if they are 
care. 
providing direct patien  o exemp  cer  ain 
Provisions  physician 
physicians from 
 his requirement (e. g.,  working
in foreign countries) should be considered.

Physician disclosure reqiremen 
s wi thin an agency should be
uniform across all organizations and personnel sys 
ems.
Organiza  ions should reques  more in-dep 
h disclosure of 
adverse prac ice history information from applican 
pDiscrloesurce quiesstieons  smhould abe nwrie  r.  en in a clear and

To assis  his
endeavor the organzations in

, a suggested disclosure questionnaire has been 
developed and is con ained in Appendix 8.

The curren  licenses held by a physician applicant should 
alilcweanyss inbeg  vbeoraifridesd.  direc ly wi th  he appropria e S ate
Organiza 
ions should also con act primary 
o verify medical degrees and completion of

soureces sidency progams. 
he organzations 
Mos  reviewed should s  rengthen
verifiofca 
ion procedures by developing wri  en guidelines to
be used by personnel involved in verifying physician
qualifications. 
Verification of disclosure information 
should include accessing na ional physician da a bans such
as FSMB' s disciplinary data base or the 
AM' s Physician
Masterfile. 
iii
 All agencies should screen physician applicants and 
periodically screen all physician employees against the 
Ban, 
federally-operated National Practitioner Data  when
operational. 
The bank is mandated by The Heal th Care 
Quality Improvement Act of 1986 and The Medicare and 
1987. 
Medicaid Patient and Program Protection Act of  This 
activi ty should be coordinated with all personnel systems
and organizations operating wi  all 
thin the agency to ensure 
physicians are screened. 
COMMS: 
We received comments regarding the draft report from 13 of the 15
organizations reviewed. In 
addition, we also received comment 
Force. All 
from OPM and the Air  respondents agreed with the
report. 
recommendations contained in the  Four of the 
organizations reviewed indicated that they will be taking
specific action to strengthen policies and procedures pertaining 
to physician requirements for clinical 
positions, disclosure
requirements, and verification of physician credentials. The 
remaining organizations stated that all or part of the
recommendations were already being followed wi 
thin their 
organizations: however, they would continue to evaluate their
policies and procedures. 
Specific comments regarding agency and 
organization reactions to the recommendations appear on pages

20-23 of the reportG

The OPM indicated in their response that they will be reexamining

the Medical Officer qualifica ion standards and one of the key

issues that will be addressed is the need to require clinical
care physician to 
maintain current, valid licenses. 
than 
We wish to  those that commented on our draft report. 
Many
of the suggestions to help clarify and strengthen the text have 
been incorprated into the final report.  TABLE OF CONTENTS

Page 
EXECUIVE SUMRY 
INTRODUCTION 
Purpose
Background
Scope and Methodolog 
IIo 
FINDINGS 
Physician Qualifications 
Disclosure Requirements 
Verification Techniques 
III. 
RECOMMNDATIONS 
IV.  APPENDICES 
Departmental Statistics 
Medical Officer Disclosure Model 
c.,  Description of the Federation of 
State Medical Boards' Disciplinary
Data Ban  INTRODUCTION

PURPOSE 
This inspection was conducted at the request of the President' 
Council on Integrity and Efficiency to: 
identify Federal personnel requirements for physicians

seeking full-time employment: 
identify techniques used by organizations in verifying 
credentials and other information requested from applicants;
and, 
identify best practices that can be shared by the Inspectors

General with their respective organizationso

BACKGROUN 
In recent years a number of events have occurred that indicate
both the governental 
and private sectors need to increase their
scrutiny of physician credentials. They are as follows:

identification by the Federal Bureau of Investigation (FBI)
of physician " bos 
diploma mills, " schools selling  medical 
degrees (" Fraudulent Credentials: Federal Employees,
hearing before the Subcommittee on Health and Long-Term 
Care, April 1986); 
concerns about the adequacy and authenticity of the 
education received by graduates of foreign medical schools 
Medical Licensure and Discipline: An OVerview " report
by the Deparent of 
Health and Human Services (HHS), Office
Inspector General (OIG), June 1986, control number P-Ol
86-00064) ; 
pol 
an increasing  of unlicensed physicians practicing
medicine ("
Strengthening Educational and Licensure Standards
for Physician in 
New Jersey, " report by the New Jersey
State Board of Higher Education and the State Board of

Medical Examiners, March 1987 and "Medicare and Medicaid

Payments for Physician Services Rendered by Practitioners

who had Lost Legal Authority to Practice in the State of

Florida, 
" report by the HHS, OIG, August 1987
, control
number A-04-87-02011); 
an increase in the number of malpractice suits filed against

medical doctors each year ("
Report of the Task Force on
Medical Liability and Malpractice, " HHS, August 1987):  , "

a 60 percent increase in physician license revocations 
taken by State boards since 1984 (study conducted and 
published by the Federation of State Medical Boards 
(FSMB) 
Tribune , November 9, 1986); and 
reported in the Chicago 

a recent article in the February 11
The New

entitled,  1988 edition of 

England Journal of Medicine  Falsification of 
Clinical Credentials by Physicians Applying for Ambulatory 
Staff Privileges, " which reports 5 percent of the 773 
physicians reviewed presented false clinical credentials. 
Three and one half percent gave false information about 
their residency, 1.3 percent falsely reported board
certification and . 
3 percent provided false information 
about both residency and board certification. 
Congress has focused its attention on protecting the public from
imaired, 
unqualified, and unethical physician. According to
reports by the Congressional Subcommttee on Health and Long-Term
Care and by educational agencies regarding fraudulent 
credentials, 1 in 50 physicians may have used some form of 
fraudulent credentials in seeking employment. These reports also
note that while most United States businesses emphasize 
educational levels when making employment. decisions, most do 
nothing to verify school credentials. 
Congress passed The Health Care Quality Improvement Act of 1986 
and The Medicare and Medicaid Patient and Program Protection Act
of 1987. 
These laws will facilitate the verification of 
physician information presented on resumes and application forms. 
Most of the medical officer positions located in the Federal 
agencies reviewed are filled by physicians in clinical, patient-
physician 
care settings. The next largest group of  are 
researchers and investigators in nonclinical positions, followed
by progam administrators 
and managers who supervise staff
physician or 
formulate policies and procedures. 
Physmiciainns ia pplying for positions in Federal service must meet
the  reqirements 
established by the personnel systems
under which tahn so rganzation' operates. Most of the organizations
reviewed in  s'tdy operate under a combination of two of the
fOllowing personnel systems: the 
civil service, the Commissioned 
Corps of the Public Health Service (PHS), and the military
instance, the Deparent of 
services. For  Defense 
militar  (DOD) has
commissioned  physician and civil
officers who are 
service physician. 
The Coast Guard has both civil service 
physician and officers in the PHS Cossioned Corps. The 
Deparent of 
Veterans Administration (VA) and  State have
personnel system unquely their own. 
The VA employees receive
civil service benefits; however, VA uses its own personnel
application form 
and establishes its own personnel standards and 
qualifications. The Departent of State is under the foreign  service system, although they use the standard civil service 
forms and require additional qualifications to those specified by 
the Office of Personnel Management (OPM). Appendix A indicates
the tyes of 
personnel systems operating wi 
thin each agency. 
Verification of physician credentials and other related 
information is a somewhat complicated process because there are
layers of review. 
Typically, a physician s qualifications come 
under scrutiny by personnel specialists who screen the 
met. 
application to ensure all personnel requirements are  Next, 
or perhaps at the same time, security personnel verify
information to ensure that the applicant is sui table for 
emploYment. Physician applying for clinical care positions may 
also need to apply to a credentialing board of a Federal hospital 
for medical privileges. Again, credentials are scrutinized 
determne the 
primarily to  medical skill and competency of the
applicant. 
Some organzations also have staff who are 
responsible for screening the credentials of all physician 
applicants before they are hired. Hiring officials receive the 
information accumulated through the preemployment process and 
make a decision regarding the applicant. However, some 
organizations have centralized medical appointment boards that 
physician 
must approve all  before they are hired. 
SCOPE AN MEODOLOGY 
ths 
The term "physician credentials,  report,
" when used in 
refers to information and documents provided by the applicant 
regarding academic background, residency, licensure and, "
necessary, board certificatioQ. The term "practice history
information refers to adverse actions taken against a physician
while practicing medicine. 
This information may include
disciplinar 
actions taken by State licensure boards, peer review 
commttees, or sanctions by Federal entities. It includes 
information regarding malpractice awards resulting from 
inurance, 
inappropriate care, denial of malpractice  censorship
by professional organzations, etc. 
This report does not focus on the entire preemployment process 
organzation. 
because it differs in almost every  However, we
compared reqirements and 
qualifications, and looked at
verification techniques which were used by personnel specialists,
securi ty specialists, and hespi tal credentialing committees. 
physician 
Since most of the full-time Federal  are employed in
clinical care positions, we focused on the verification of
credentials for these physician. 
Based on information 8upplied by OPM, we selected for review 7 
physician on staff
Federal agencies with 35 or more full-time 
as of 1985: 
(1) HHS (the Social Security Admnistration
, the 
Care Financing Admnistration
Heal th  , the Centers for Disease  Control, the Alcohol, Drug Abuse and Mental Health 
Administration, the Food and Drug Administration
, the Health
Resources and Services Administration (HRSA), and the National
Insti tutes of Health (NIH)): (2)  Ary 
DOD (the  and the Navy); (3)
State; 
Department of  (4) the Department of Transportation (the 
Coast Guard and the Federal Aviation Administration): 
(5) the
Department of Justice (the Bureau of Prisons); (6) the VA; and
( 7) the National Aeronautics and Space Administration 
(NASA).
For ease in reporting, 3 agencies, NASA, VA and the Department of
State, plus the 12 components within the remaining 4 agencies

organizations. In all 
will hereafter be referred to as 
, 15

organizations were conta ted.

Field work was conducted primarily at the Headquarters of these 
organizations with the exceptions of VA and DOD. For
decentralized organzations, 
telephone intesrtvaifewfs.  were also
conducted with selected regional or local  Because the 
General Accounting Office was concurrently conducting reviews of 
VA and DOD, we limited our contacts with these agencies to Ary,
Navy and VA officials wi thin the Chicago area and selected
Headquarters officials. (It should be noted that the Air Force
study). 
was not interviewed during this  For the most part, we
relied on file information regarding DOD and VA physician 
requirements and credentialing practices. 
Because it was not 
feasible to contact every field office, regional office and/or
medical facility operated by the sampled 
organizations, our
analysis may not reflect all local credentialing practices within 
an organization. 
We interviewed personnel directors and 
staff, security officers,

clinical directors, area directors, employee relations

specialists, tort specialists, and chief medical officers.

Appendix A lists the organizations involved in this study by

agency and indicates the approximate number of fUll-time

physician 
employed. 
application form, 
We examned 
disclosure statements, personnel
and employee reference form letters and checklists used to verify

physician credentials. In addition, we reviewed written policies

and directives regarding physician emloyent reqirements and
verification procedures, to the extent they were available. 
We analyzed 72 case abstracts of HHS and VA physicians whose

licenses were revoked, suspended or restricted before they were 
hJred for Federal service. Information regarding the VA
physician was gathered from a report entitled . Audi t of
Licensure Status of Veterans Admnistration Physician,
September 1986, prepared by the VA Inspector General. 
Information regarding HHS physician was provided by the Office
. of Audit within HHS, OIG. 
(It should be noted that the HHS
physician 
referred to above were identified as a result of the
ini  progam,  curently 
tial matching  which is  ongoing, with FSMB  and the AM' s Physician Masterfile.  Corrective action regarding

these physicians has been taken.

The military, the PHS Commissioned Corps, and the VA have 
recently revised their physician qualifications and verification 
procedures. Many of the best practices identified in this report
reflect these changes. 
The OPM is also currently revising the 
standards and qualifications required of civil service 
physicians. We hope this report can further assist these 
organizations in refining their credentialing processes.  II. 
FINDINGS 
PHYSICIAN QUALIFICATIONS

Finding: 
he personnel sys ems reviewed require physician
Aallpplican  o mee  he same minimu educa  ional and 
licensure requiremen  hey are applying for 
s if 
ions . 
clinical care posi 

The minimum requirements are as follows:  a degree from an
accredi ted medical 
school, completion of an approved internship
and/or residency program, and possession of a current, valid,

unestricted state 
medical license. 
An accredited medical school is defined by all the personnel 
system as a United States or Canadian medical school approved 
by the Liaison Committee of Medical Education during the year the 
applicant graduated. 
Applicants graduating from foreign or unaccredited medical

schools must demonstrate to reviewing officials that the medical 
education and knowledge received is substantially comparable and 
equivalent to that offered by an accredited medical school as
defined above. Comparability may be evidenced by a valid,
unestricted 
State license: specialty board certification: 
permanent certification by the Educational Commission for
Foreign. Medical Graduates 
(ECFMG): or, 1 year of service as an
comissioned 
active duty  medical officer in the medical corps of 
the military or the PHS Commissioned Corps and performance of
unestricted 
duties including the treatment of patients. 
An approved residency program is defined by the personnel

systems as one that was approved by the Accreditation Committee

on Graduate Medical Education during the applicant'
s period of

participation. Usually the applicant must have completed no less

training. 
than 1 year of approved residency  However, exceptions
are occasionally made. 
Personnel systems, with the exception of the PHS Coissioned 
Corps, did not usually require an applicant applying for a 
research position to possess a current license unless the 
research would include patient care activities. On the other 
hand, many organizations required licensure for physicians 
admnistrative 
applying for 
positions where they would be
supervising patient care settings, or rotating be 
een clinical 
assignents. 
and administrative 
reqire 
Five organzations have some positions which  applicants
to have specialty board certification to .eet the 81nium 
reqirements. However, this qualification is not reqired for
all positions within these organizations. Others "
reward" board-
certified physicians by allowing them to enter Federal service at  -, 
higher grade levels or pay physicians bonuses for such

credentials. 
Uni ted states citizenship is required by all the personnel

systems. 
Occasionally this requirement is waived by civil 
service if the physician is otherwise qualified and will be

placed in a "hard to fill" position in a medically underserved

area. 
Finding: 
Civil service is the only personnel sys  does
reqire 
cuen  physicians, once  oem  main ain
emloyed, 
, valid licenses. 
The PHS Commissioned Corps requires commissioned officers to 
Maintain current medical licenses regardless of whether they are 
working in clinical, research or administrative positions,
physician 
although exceptions, usually for  holding research 
basis. 
positions, may be made on a case-by-case  The military,
Department of State and VA, with certain exceptions; e.g., 
physicians working in foreign countries), require their clinical
physician to 
maintain current, valid licenses. However, civil
service physicians, once appointed to clinical positions, do not 
need to maintain their medical licenses with the exception of 
those working in the District of Columbia. On the other hand, if
a civil service physician applies for another competitive civil 
service job which requires licensure, then he or she must possess 
a current, valid license to be eligible for the position. 
It should be noted that the above finding applies to personnel 
systems in general. Civil Service physicians in clinical care
posi tions employed by PHS, DaD, VA and the State Department are
required to maintain medical licenses because 1 
t is a uniform

policy of these agencies.

DISCLOSUE REQUI 
J'iDing:  Phy.ician di.closue r8qir  . var widely. 
There 
unfora ty 8Ing 
i. DO  per.onnel 8y.  agencie. or
.08 organza ion.. 
While all personnel systems serving the organzations reviewed
have established unform 
minimum requirements for physician
applicants, each system reqests additional information. Chart
1 on page 8 comares disclosure reqirements of the military, 
Co-i ssioned Corps. 
civil service, and the PHS 
 reqires  As this chart 
indicates, the military  the most disclosure by its
physician applicants. Of the 13 areas listed, only the following
are uniformly reqired by all 
personnel system to be disclosed:
( 1) felony convictions, ( 2) courts-marial convictions, ( 
3 )
misdemeanor convictions, ( 4) professional references, (5)
violations of Title 21, u. S. Controlled Substance Act, and (6)
license. It 
revocations of a State medical 
should be noted that  disclosure of the first four items are required of all applicants 
fif 
applying for Federal service, and only the  h and sixth items 
are specifically addressed to physicians. 
CHT 

DISCLOSURE REQUIREMENS BY PERSONNEL SYSTEMS. 
Civil 
Hi 1i1:ary
Inform1:ion Required  Service  Corps  Services 
MEICA 
LICENSUR 
Nul tiple Licenses 
License Application Refused 
DBA CONTOLLED SUBSTANCE PERIT 
Registration 
Denial/Surrender /Loss of 
Permi t 
PRACTICE HISTORY

Convictions:
Felonies/Courts-Martial
Misdemeanors 
Substance Abuse Violations

Torts 
Licensure Problems:

untar 
Vol  Surrender
Invol untary Actions 
Privileges Problems 
Professional Association/Peer
Review Problem 
Professional References

*Most of  e organzations reviewed operatet husnd ecrh aa rcto.m bination

of two of the three personnel system on  The
personnel system 
used by the Department of State and VA 
cluded because each is unique to its own agency. 
were not 

We also found no consistency in disclosure reqirements 
among the
agencies studied, nor consistenCy amng organizations wi 
in an 
ere was rarely consistency wi1:n
agency. In fact, 
 e Deparent of 
organization itself. 
State have 
consistent disclosure rOnley qVA uanid rements of all physician applying for
positions. The DOD has unifAorrm  directives regarding
credentialing: hoever the 
and the Navy have added their own  specific requirements which pertain only to those applying for
military positions. Civil 
service applicants within military 
organizations must meet only DOD/civil service requirements. 
Wi thin HHS organizations, there are similar inconsistencies 
caused by the requirements of the civil service and PHS 
systems. 
Commissioned Corps personnel  The NIH has addressed the
si tuation 
by imposing uniform requirements on all physician 
applicants regardl ss of the personnel systems operating wi thin 
this organization.

Chart 2 compares the disclosure requirements used by the 15

organizations studied. Only six consistently require all

physicians to disclose all States where they currently hold or

have ever held a State medical license. Only three consistently

ask about any malpractice claims or settlements 
None asked 
about Medicare/Medicaid sanctions: however, the Bureau of Prisons

indicated they did screen physicians against the Medicare/ 
Medicaid sanction listing. only two organizations consistently 
inquired if a State license had ever been voluntarily
surrendered. 
Three organizations consistently asked if hospital 
privileges had ever been revoked or suspended, and only seven.
drg 
consistently asked applicants if any State  laws were ever
violated. 
CB'r 2

ORCUID'IIONS' DISCLOSU UQUI 
If
IDfoZ''tiOD Reqred  GrgaDi.a'tion8 
LICE 
MEICA 
iple License.
NLul ic8fe Application(.)
Refu.ed 
Dn 
COIfOLLED

SUBSTANCE PERI'!  Regi.  ion

Deal/Surender /Lo.. 
. PUC'ICB BIS'RY  Convic  ions:
Felonie./Cours-Marial
M1.d_eanrs
'rort. 
Sub.tance Abu.e Viola ions
Mecare/Mecaid. Santions
Licen Prbl_:

Voluntar Sur8Der 
InvluntaPr rAbclt.i.on

Privilege. 
Insance Probl-
Profe..ional Assoiation or 
P_r  Probl.. 
Rev1e"
Prfe..ionl
R"'erene. Ar 
The NIH, VA, the  and the Navy have more comprehensive 
disclosure requirements, thus allowing their hiring officials to

make a more educated assessment of the potential risks to the

agency posed by the . applicant. 
In examining how physicians with disciplinary histories had 
slipped through employment screens, the OIG/VA and OIG/HHS found 
among other problems, that more extensive disclosure could have 
prevented certain physicians from entering Government service. 
For instance, one case involved a physician who had a history of 
license. In all 
voluntarily surrendering his medical  States 
where this physician "voluntarily surrendered" his license, he 
did so after being confronted by the state medical board for 
indecent assault on a patiaent.v Wi thoin 3i yedars oef obdtaini.ng  a 
Federal position, this same physician was terminated for sexual 
harassment. Had this organization properly inquired concerning
mul tiple licenses and their status, the risk associated with this 
physician could have been 
rinding:	 All organsa  o sign .  ..en
ioD. require app1ican 
iDdica  and 
dingia  e deyiS U8Dsdsears1  or pelty ey will be .ubjec
for false disclosure. 
Most of our respondents agreed that use of disclosure is a good

screening
" technique. One respondent stated his organization 
used disclosure statements to discourage physicians with 
histories of disciplinary actions. When confronted with 
answering the questions truthfully or facing a penalty for false 
disclosure, they found physicians often withdrew their
applications. 
All organizations require appricants to permit the release of 
information from past and present employers, schOOls, law
enforcement agencies and other individuals and organizations. 
For clinical care applicants, the NIH requires information from 
administrators and members of medical staffs of other hospitals
or institutions, .edical 
associations, malpractice carriers, the
AM,  recogzed 
FSMB and other nationally  bodies that maintain 
automated data files on clinical care practitioners. 
The NIH' s, VA' 8, and the Ar' s attestation form reqire the
physician' 
s agreement to release from liability all entities, and
their representatives, from actions performed in good faith and 
thout malice. 
wi  Such a release clears the way for an employer to 
verify an applicant' s credentials, competence, character and
professional ethics.  . .
Finding:  Diacloaue reqea  a are of 
aiD  erpre  ioD .  en open

In comparing the various disclosure questionnaires used by the 15

organizations, some allowed the applicant to  provide a less than

complete and truthful response.

Following are examples of questions regarding professional

liabili ty:

Have you had any malpractice claims wi 
thin the last 5 years 
or is a claim pending?" 
Have you ever had any malpractice actions instituted

against you?"

rTheeq feisrstt.  example places a  year limitation on the disclosure
Serious violations of professional conduct and 
instances of medical incompetency could have occurred prior to 
the time period specified. Nei ther example requests past and 
present liability claims/judgments/settlements made against a
hospital, corpration, or Governent, based 
on a case directly
under the applicant' 
s care. 
porly 
Some examples of  crafted questions concerning multiple
licensure are: 
and: 
current, valid, unestricted 
Do you hold a  licensee s) to 
porra ctteircrei tomerdyi(csi)n?e,"  dentistry, or podiatry in a U.S. State(

/unestricted professional
List States granting ful 
licenses/ certificates. " 
Many physicians, especially those in the early years of their 
licenses. 
practice, hold up to three or four State medical  While 
it is not unusual to find a physician not renewing some medical 
licenses as his/her practice becomes mere established in a given 
State( s ), one must guard against the incompetent and/or 
unprofessional physician who voluntarily surrenders his license 
in one State only to set up practice in another State in which
he/she holds an unestricted 
medical license. By limiting the
disclosure to "full/unestricted" or "curent, valid, 
unestricted" one has provided a loophole for the physician

applicant to avoid divulging past or present restricted, 
suspended, revoked or voluntarily surendered medical licenses. 
In one situation, the application form itself allows apace for
listing thee State licenses. Ths 
allows the physician to avoid
divulging the State(  disciplinar actions 
s) that have taken 
thse 
against him/her, by listing only  States where he/she has an
untarnished record.  ...... ...
Wi th respect to disciplinary actions taken against a physician 
license to practice medicine, one organization requests a

physician to disclose if his/her license has ever been

lost/revoked. 
Such disciplinar actions as suspension or
restriction of a medical license or denial of such are not

requested. 
Many of the disclosure requests/questions begin with:

Has your license

Has your application

Is your license

If a physician has more than one license or has filed

applications for more than one license, then the physician could

respond to the disclosure questions by referring only to those

State licenses and applications for licensure where he/she has an

untarshed 
record. 
Appendix B contains a suggested disclQsure questionnaire with 
sample language for each inquiry. The model is based on the
strong disclosure reqirements 
used by NIH and the military. 
VEIFICATION 'lCHIQUES 
Finding:  Verifica  eciques  var
ioD. 
used by organiza 
widely. ioD 
rew organllziac aioln .' cOD8i.  ly COD  primry 
o verify 
degree., re.idency 
.ource.  ifica e. or licenure . atu.. 
Any  one or combination of the fOllowing techniques were used to
verify particular information: 
( 1) visual inspection; (2)
reqests 
telephonic confirmation: (3) written  (vouchers): (4)
National Agency Check and Inquiry 
(NACI): (5) background
investigations;  part data bans: 
(6) accessing third- and (7)
listings. 
screening against approved 
tially screened the application said they

Most respondents who 

looked at the form to ensure all the necessar information 
was
present for a determnation whether the applicant met the
soe  ths 
necessatrhy sq upalairficicualtairo npsh.a sFeor o f theo vregrainfiiczaattiioonns p, roceswsa.s  the
end of 
For
others, if "something didn' t look right" furher inquiry was
made. 
All organzations sent letters 
to physician-supplied references.

A few organzations indicated 
that references were called 
directly. One organzation 
developed a form to soliciFt u.peercific
information regarding the applicant over the phone. 
information regarding reference fOllow-up is contained on

page 16.  Verification of medical education usually consisted of review of 
a submitted copy of the diploma and residency certificate.
However, recogizing that 
copies of medical degrees and
certificates can be forged or 
altered, the Joint Commission on
Accredi 
tation of Health Care Organizations requires effective 
January 1, 1988 as a standard of accreditation
, that hospitals
use primary sources such as medical schools and residency 
programs to verify the qualifications of doctors seeking clinical
privileges . 
Several respondents indicated that State licensure boards were 
contacted to verify the status and validity of the current
license ( 
s ); however, only the military and VA contacted
applicable State boards to determine the status of all current

and past licenses held by an applicant. In addition to
verification of licensure 
status, for military physician
applicants, the Ary 
and Navy verified, from primary 
sources, the
rest of an applicants credentials, including requesting

schols 
transcripts from all 
(including foreign schOOls) and
checking with the AH
, ECFMG and specialty boards to verify
school accreditation, completion of an approved residency 

and, if

necessary, board certification. 
A physician is not officially

hired until the entire verification process is 
completed. 
An analysis of HHS and VA case abstracts indicates that

contacting appropriate third parties to verify medical degrees

and licensure could have prevented unqualified physicians from

entering Federal service. 
To illustrate, an investigation of the

circumstances which left a surgical patient in a irreversible

. coma due to brain damage revealed that the Federal physician who 
administered the anesthetic during surgery was not a 
physician.
Before this physician was emplpyed by the Federal Governent, the
bos 
dECFeMGg wars eawaere  thfat rthois mph ysiaci an f
 oreign medical school.p oster had a  medical
This same person
repeatedly attempted to obtain a medical license in different 
States but failed to pass licensing exam. 
Despi te failing to
obtain an ECFM certificate and repeated failures to obtain a
State medical license in ..veral 

doents  s person presented

- forged foreign  and obtaStiatens, ed a position vi 
Governent.  th the
Had the emloying organzation not relied 
on copies
provided by the applicant and verified credentials by contacting

independent sources, 
 ster could have been exposed,
denied Federal emloyent, 
and not allowed to endanger patients. 
Finding:  nU8r 
pby.iciaD o'f  .re 8pnccdern'et.b den 'tial. av..U8e  re ver'itfi'etd a 'ltlo uogr hpa't of a
8U 'tbili 't  or backgroud inv..'tiga'tioD8. 
All Federal emloyees must undergo a secuity check or acme form
of background investigation. Most of the 
physician emloyed by
the organzations reviewed were classified in nonsenitive  posi tions which do not require extensive background
investigations.

Physicians occupying nonsensi ti ve positions receive a basic

NACI. 
securi ty check referred to as a  The OPM has the 
responsibility for conducting NACIs, although certain Federal 
organizations have made arrangements with OPM to conduct their 
own NACIs. The NACI consists of: 
a written request (called 
voucher) for verification of 
highest educational level or degree achieved: 
vouchers to all schools (if any) in the last 5 years:

vouchers to all employers (if any) in the last 5 years; 
and, 
name check of OPM records for results of investigations 
conducted by other Federal components: 
files.. 
name and fingerprint search of FBI 
Eo. 
tabili ty 
An HACI sui  check is not designed to determine whether a 
licensed. 
physician is properly  Those physician who have 
graduated from foreign schools and whose emploYment references

are outside the Uni  States may have none of their professional

qualifications verified because the NACI does not verify foreign

education or foreign emploYment. Some components incorrectly

assume that the NACI constituted verification of credentials. 

components want credentials information verified they may request

OPM to include it in the NACI or seek verification through other

primary sources 
The Departent of 
the Bureau of Prisons, and Coast Guard 
State 
have classified all medical officer positions as sensitive or 
higher and thus perform full background investigations on each
physician.  senitivity 
However, this  level is required of other
professionals in these organzations, and dos 
not reflect

special scrutiny of physicians.

Raising the sensitivity level of positions occupied by physicians 
, unalified, 
may reduce the risk of unethcal or impaired
Goernent 
physicians entering  service, but will increase the 
physician 
cost of the investigation. The NACI for  occupying a
nonsensitive position costs about $15 to conduct. Raising the
sens! ti vi ty designation to the next higher level would add a 
credit check, increasing the cost to about $100 per physician. 
More in-depth background investigations can cost up to $2, 000 or 
more depending on the scope and depth of the investigation 
dos 
. desired by the  le OPM  not charge
organzations foorganrzati on. 
conducting MACIs, the cost of any . check. or 
investigation above the level of a NACI must be assumed by the  organization. As detailed in the next finding, there are other

verification technques available. 
Finding:  Sam organiza  ion. access independen 
verify physician creden ials and adverse pa brana. 
c ice
his  ory inform  ion. 
The three agencies employing the most physicians, VA, HHS, and 
DOD , screen all physician applicants against a disciplinary data 
bank operated by the FSMB. This bank serves as the primary 
center for collection, maintenance, and reporting of disciplinary
actions taken against physicians resul 
ting from formal charges by
FSMB member boards and other governental authorities. 
( See
Appendix C for more information regarding this data ban. 
The FSMB' s data pertains only to disciplinary actions taken

against licensed physician or physicians applying for a license
It 
canot identify 
whether a physician holds a license at all qr 
is licensed in a given jurisdiction if no disciplinary actions 
have occured. Direct confirmation with the licensure board is 
status. 
the best method of verifying licensure 
Many organzations who employ fewer physicians were not aware of

this disciplinary data base. 
Others which did not use it 
expressed dissatisfaction with the accuracy and the relevance of

the information available. Those organizations who use it as a

screening tool were generally satisfied but did express some

concern about the uniformity of the data reported.

One organzation reported difficulty in following up with the 
State licensure boards on a potential "hit" from the data ban. 
The hit resulted from information supplied by the licensure board 
regarding a physician who voluntarily surrendered his license. 
Many state licensure boards will not release information 
concerning their investigations when the physician in question
vOluntarily surenders 
a- license to practice medicine before the 
board completes its investigation. Simlarly, many Federal
organzations will 
not release information when physicians 
voluntarily terminate their employent rather 
disciplinar  than face
involuntar 
action and possible  removal from Federal
service. 
Another data base used by many of the organzations is the AH 
Physician Masterfile, which profiles a physician 
s education 
training, board certification, memberships, and biogaphical
information. It also contains limited licensure information, and 
indicates whether the physician died in the last 15 years. 
Special ty board certification can also be verified by purchasing

a compendium of board certified physician prepared by the
AIlmlienriocains .B oard of Medical Special ties located in Evanton,
However, the most current and accurate information  regarding board certification can be obtained directly from the

appropriate specialty board.

Pinding:	
Form letters (vouchers) used by most organizations to 
contact references do not obtain all 'te needed
informtion. 
The letter the Coast Gfuoarrd:  sends to professional references

specifically queries  (1) confirmation of staff privileges
and any restrictions/limitations: (2) clinical/professional
reputation; 
knowledge; (3) professional  (4)
professional/personal ethics; (5) ability to work with colleagues
and staff: and, (6) the ability to communicate with the patients.
The Department of State letter specifically asks about any
disciplinary actions. 
On the other hand, a standard form that is 
used by many organizations has a checklist with items like 
wcrai ptatecin  tcyo fmore ndtesv edloo pnmoent t, " and "attendance.  The sections for
focus on professional ability,
reputation
, or any disciplinary actions. 
Pining:	
PersoDDelp 8aaura, ls, hadbooks and directives are, for 
'te most  silent regarding how to verify physician
credentials. 
Most of the organizations reviewed in this study operate a number 
country. 
of health care facilities located across the  Generally,
the preemployment process for physicians starts in local 
personnel offices. From there, the process becomes somewhat 
fragmented in that certain tasks in verifying a physician 
credentials are done by local staff and others by Headquarters
staffe 
physician hired 
The number of  may vary from facility to
facili ty e. Many of the local personnel offices may process only a
few physician applications a year. 
Therefore, personnel
specialists may have limited familiarity with the complexities of
physician credentialing. 
Personnel manuals, handboks 
and directives do not often 
stipulatAe hrow  to verify a physician s credentials. Only PHS,
VA, the  and the Navy have developed written guidelines to be 
used by employee specialists in screening and verifying 
physician credentials. These 
guidelines stress the importance of

verifying all information obtained from applicants with primary 
par 
sources, or thrd- sources such as the data bans previously
described. 
The PHS guide lists verification sources, indicates how to
tye 
access them, and contains examples of the 
of information
available. The  coments 
guide also provides a list of  and 
questions that personnel specialists should use in assessing the

information collected to determne if the applicant is qualified

and sui table for employment.
 Findg:	
aecent: legislat:ion has expanded 'te independent: -ourees
credent:ials verificat:ion. 
available for 
The Health Care Quality Improvement Act of 1986 requires that

paid medical malpractice actions and claims be reported to the

Secretary of HHS. This Act also requires health care entities

wi th formalized peer review mechanisms to report to the

Secretary, through the State licensing boards
actions they take against physicians.  , disciplinary

The State licensing boards
must review these health care entities ' referrals and, if
warranted 
, take disciplinary action. Any disciplinary action
taken by State medical boards must, in turn, be reported. The
Secretary will maintain and make this information available to

hospi 
tals and certain other heal th care providers. 
Federal agencies submitting data or accessing this data bank

must: 
1) use due process in a professional review acti 
w (  vi ty or 
its equivalent for its actions to be accepted by 
 e bank: 
and	
( 2) have 
an approved Privacy Act system of records for (a)
tting data to the ban 
submi 
if it is to do so one for (b)
obtaining data from the ban 
if it is to do so. 
The HRSA will oversee the operation of the National Practitioner
Data Ban 
and organizations will be subject to user fees before 
ban. 
they may access the 
The Medicare and Medicaid Patient and Program Protection Act of

1987 expands the provision of The Health Care Quality Improvement

Act of 1986 regarding disciplinary information by permitting the

Secretary to gather information concerning:

licening 
(A) Any adverse actions taken by such  authority
as a result of the proceeding, including any revocation or 
lengt of 
suspension of a license (and the 
any such
suspension), repr  and, cenure, or probation. 
e B) Any dismssal or closure of 'te proceedings by reason of
the practitioner or entity surendering the license or
leaving 'te State or jurisdiction.

e C) Any other loss of the license of the practitioner or 
entity, whether by operation of law, vOluntary surender
otherwise.  , or q)),

The iaw also allows for the dissemination of such information: 
" ( 1) to agencies administering Federal heal th care programs 
including private entities administering such programs under

contract, 
( 2) to licensing authorities described in subsection (a) ( 1 ) , 
(3) to State agencies administering or supervising the 
administration of State health care programs (as defined in 
section 1128 (h) ) 
( 4) 
to utilization and quality control peer review 
organizations described in Part B of Title XI to 
appropriate entities with contracts under section l154
( a) ( 4 ) ( C) with respect to eligible organizations reviewed 
under the contracts, 
( 5) to state medicaid fraud control units (as defined in 
section 1903( 
( 6) to hospi tala and other health care entities (as defined 
in section 431 of the Health Care Quality Improvement Actt hof  
with respect to physicians or other licensed heal 
1986 ), 
care practitioners that have entered (or may be entering)
into an employment of affiliation relationship with, or have 
applied for clinical privileges or appointments to the 
medical staff of, such hospitals or other health care 
pentritoiesv (ainsd isuoch ninfsor moatifon,  shtahll abet . dAeemedc tto )be,  
disclosed pursuant to section 427 of, and be subj ect to the
(7) to the Attorney General and such other law enforcement 
Secretar 
officials as the  deems appropriate, and 
reqest, to the Coptroller 
(8) upon  General, in order for 
such authorities to determine the fitness of individuals to 
provide health care services, to protect the health and 
though 
safety of individuals receiving health care  such 
progams, 
and to protect the fiscal integrity of such
progams. " 
reglationS 
Proposed Federal  pertaining to the Health Care 
released.
Quality Improvement Act of 1986 have recently been 
Federal reglations  Progam Protection
regarding the Patient and 
Act of 1987 are under development. 
Therefore, details regarding
the tye 
of information that is to be reported have not yet been 
widely dissemnated. However, most of the information currently 
being reported to FSMB will also have to be rteyposr ted to the
Secretar of 
HHS. 
Appendix C describes the  of information 
ban. 
contained in FSMB' s disciplinar data  Addi tional informa ion regarding the operation of the Federal
bank and the information it will contain can be ob ained 
from: 
Office of Quality Assurance 
Bureau of Health Professions 
Resources and Services 
Heal th  Administration 
Room 8-15 Parklawn Building

5600 Fishers Lane

Rockville, Maryland 
20857 
(301) 443-2300
 I:II .  RECOMMATIONS

Agencies emloying 
Recollenda tiOD:  civil service, clinical care 
pchuyseincita,n s should require 'tem to ..intain

or, 
valid State medical licenses;  'to be 
system, 
consistent wi't o'ter personnel 
OPM 
should require all clinical civil service

physicians, once emloyed, 'to main'tain a curren
medical license. 
The military, VA, Department of state and the PHS Commissioned

Corps personnel systems (all with certain exceptions) require 
clinical care physicians to maintain their licensure status while
employed. Only 
civil service does not. It is inequitable that
physicians working side by side in an organization
, with the same

duties and responsibilities, are subj ect to different licensure

requirements because they were hired under different personnel

systems. 
Physicians in private practice or employed by non-Federal health 
institutions are all required to have .medical licenses and renew 
them when necessary. These same physicians are subj 
set to 
renewal requirements, such as continuing education, and 
disciplinary actions mandated by the state licensure boards. 
pol 
These requirements not only help to reduce the 
of unlicensed 
physicians in this country, but also enhance quality assurance 
COllents: 
recomendation. 
All respondents concur with this  One 
organization indicates that they will be pursuing the policy of 
requiring civil service physic,ian within their organization to 
licenses. 
maintain valid  This is consistent with requirements
for civil service physicians in clin cal care positions working

for DOD, PHS, VA, and the Department of State.

The OPM ind cates they wil  be reexamining the medical officer

qualification standards under civil service. One of the key

reqire 
issues that will be addressed is the need to  clinical 
care physicians to maintain curent, valid licenses. 
reqr..nts 
RecOlendation:  'tin
Physician disclosure  wi 
agenies 
should be unifora across all 
organsations and persoanel services. Most
organsations should reqest IIre in-depth
discloaue of 
advers. practice history
iDfoZ'tion fr08 applicants. Discloaue 
pquresctiisoen  8s8heoru.d  be WZi tten in . clear

The extent to which clinical care physician applicants are 
required to disclose adverse practice history informtion varies  grea  ly even wi thin organizations. Adverse practice history 
information may not necessarily disqualify the physician from 
employment. However, in determining a physician s medical
practice "
track record, " it is important to obtain as complete a 
profile of an applicant as is possible. To assist the 
organizations in this endeavor, a suggested disclosure 
questionnaire has been developed and is contained in Appendix 

Commen 1:s : 
All respondents agreed with the intent of this recommendation. 
One organization indicated that they would review their current 
application package to determine which of the questions on the 
incorporated.
suggested disclosure questionnaire might be 
However, it appears, based on the comments, that not all agencies 
are taking s eps to ensure uniform disclosure requirements across 
their agency. 
all organzations within  Differences will still 
exist in some agencies depending on the personn,l system under 
applies. 
which the applicant 
'!e 
Rec08enda1:ion:  IIS1: cuen1: lic-.ses held by an app1ican1: 
abould always be verified direc1:1y with the
appropria1:e S1:a1:e licensing board. prim
Organza1:ioDS should also con1:ac1: 
sources  verify 88ica1 
1:0  degrees and 
prog88. 
c08le1:ioD of residency 
Few organizations consistently verify academic and licensure
credentials with primar 
sources such as registrars ' offices or
licensure boards. 
The case abstracts we reviewed show that such 
verification would have helped the employer avoid making an 
ecision. 
erroneous or dangerous hiring 

COllen1:s : 
that, in the futue, 
One respondent advised us  they will include 
in the full field background investigation .verification of a
physician  s license though individual 
State licensing boards and 
(verification of) adverse practice history el1ci ted from the
applicant. . 
Another respondent advised us that, effective January 1, 1988,

the Joint 
 ssion on Acrcerqediirtea tion of Heal thcare Organizations
changed its standards to  that physician credentials be 
primary  issuing authorities. This standard is in 
verified with 
 year. 
the implementation phase during this first  Following that,
medical facilities which do not ctohmspl y will jeopardize their
accredi tation status. Based on  information we have revised 
advates to
the text of our report by changing the word 
requires.  Recommenda  ion :  Mo.  of the organiza ions reviewed should
rengten verifica 
ion procedures by 
o be used by 
developing wri  en guidelines 

personnel involved in verifying physician
ions. 
qualifica 
Verification of disclosure
informtion should include accessing national 
a bans 
physician da  such as FSMB' S disciplinary
a base and the AH  erfile. 
Physician Mas 
Physician credentialing is a complicated process. 
Many personnel 
specialists process only a few applications each year and may
have limited familiarity. 
with the complexities involved or the 
available. 
verification sources  Some respondents assumed 
incorrectly that the NACI constituted verification of

credentials. 
Wri tten guidelines for verification procedures would provide 
guidance to less experienced personnel specialists and reduce the
variabili ty of verification 
techniques which we encountered. 
C08n 
s : 
One agency that curently has 
guidelines that mandate

verification of qualifications with outside authorities will

consider contacting primary sources for future verification of

physicians ' credentials. 
Anther 
respondent, in commenting on physician credentials 
verification in general, felt that OPM "should issue
governentwide regulations  credentialing physicians, rather
on I
than each agency issuing its own.  The OPM, in their response to 
us, indicates they consider DOD policies and procedures regarding
physician credentialing exemplar. 
They plan to make these
procedures. knwn to 
all agencies employing civil service
physician 
and recomend that they follow these guidelines as
appropriate.

Ar, 
in their coents, 
The 
indicate that they will gladly

provide details regarding m dical quality assurance and 
verification of professional qualifications to any agency or 
area. 
organization desiring assistance in this  The PHS 
guidelines entitled "Manual for Preemployment Screening of
Physician ' Credentials 
" is also available upon request. 
A number of respondents felt that the use of physician data bans 
such as the AM' s Physician Masterfile or  disciplinary
FSMB' s 
data base should not saurpe rsede verification of a physician' 
or issuing sources, i. 
credentials with pr  , medical 
8chools and State licensure boards. We agree that information
regarding physician credentials provided by the applicant during 
the application process should be verified directly with the
primar 
sources. As indicated in the report, FSMB' s data base  can 
identify whe her a physician holds a license at all or is
licensed in a given jurisdiction if no disciplinary actions have

occurred. 
ionally operated data bans 
However, use of na 
can
provide informa  hat will confirm a physician 
ion  s disClosure of
adverse practice history information or indicate whe 
her the 
hheld any pertinent information. 

physician wi 

Use of the AM' s Physician Masterfile provides additional

biographical information and of more importance
, if known, will

indicate whether the physician has died in the last 15 years.
This may indicate that the applicant is an imposter. 
Based on
these comments we have clarified the recommendation to stress

verification of disclosure information through these tyes
sources. 
Rec08lenda1:ion: 
All agencie8 should screeD physician
an 
applican1:8,  periodically 8cree all
-.loyee. 
phY8ician  federal1y
ag8in81: 'te 
opra1:ed  Ban 
Na1:io'nla81  Prac1:ice Da1:a  when
opera1:ional. 
ac1:i vi 
't should be 
coordina1:ed wi't all persoanel 
'tn  ays't- and
oergnaeniz a1:ion. opera'ting wi 
'te agency 1:0
8creeed. 
all physicians are 
Federal agencies employing large numbers of physician such as
DbOaD,n V.A  and HHS are already making arrangements to use the data
We believe all Federal employers with physicians on staff 
should avail themselves of this resource. 
C08n1:. : 
All of the respondents concurred with this recommendation and all

but two specifically stated  ey would be using the federally-

operated b  when operational.
 IV.  APPENICES
 -According to OPM survey .. of 
 Human Servicel (HHS)  Department of Heal th .nd  (DOT)	 Department of T r.nsport.t I Department of St.te (DOS)	 Department of Defense (000 Department of JUltlce (DOJ Space Administration (NASA National Aeronautics and  Veterans Administration (V Depar t8ent/Ad8ini Itr.t ion 
o ) ) ) A
n 	 	   )
	 	
1
2
/8
5
0  . ..tlon.1 Institute. of He.lth  (HRSA) - Indl.n He.lth Servic . H..lth Resources & Service. A . food & Drug Admlnlstr.tlon (FD Ad8lnlltr.tlon (ADAMHA)  , Drug Abuse & Ment.1 H- Alcohol  . Centerl for Dlse..e Control (C th Service (PHS) Public He.1  H..lth C.r. Fln.nelng Admlnlltr. locl.I Security Admlnlltr.tlo" ( (fAA)  feder.l Avl.tlon Admlnlltr.tlon  CO.lt Gu.rd  DOS  ..vy Ar.,  Ilonl lure.u of Pr  NASA  C08nta Cont.cted  fAI'"E.V ij8$Y
CNIH e (I dmln A)  e.I DC)  tlon SSA)  
) H l   

  S . (
) t H
  r C
. F
t A
lo )  'h, 
n 1 Yf
  1 u
8 3 ,  0 llclt
00 61 27 le-t
      nl
 8e
 
P
e
r
CS; PHS PHS CS: PHS CS: PHS CS: PHS CS: PHS M: 'HI  for.lgn CS: II  CS: PNI Ifn It.ry  Civil Serlonl SY
 COMMISSIONED CORPS   COMMI SSIONED CORPS   COMMISSIONED COR'S   COMMISSIONED COR'S   COMMISSIONED COR'S   COMMISSIONED COR'S
 COMMISSIONED CORPS   Service   COMMISSIONED CORPS  vice  lte.1  :t. 

APPBNDIX 8 
MBDICAL OFFICER DISCLOSUR MODEL

I f 
you answer " Yes " to any of the following questions, 
Yes 
a full statement of explanation must be attached. 
List all jurisdictions in which you currently hold

license. 
or have held a professional 
2..	 Bas your professional license to practice in any 
jurisdiction ever been limited; suspended, revo&ed, 
denied, refused renewal, issued on a temporary 
basis, or voluntarily surrendered? 
Bave liability claims been filed against you, or

against a hospital, corporation, or government based

on a case under your care? 
Bave judgments or settlementa been made against you,

or against a hospi tal, corporation, or government

based on a case directly under your care?

Bave you ever had, or are you about to have, your

professional liability inaurance declined,

cancelled, issued on special ter.s, or refuaed

renewal?

Provide the naes and addresses (past and present)

of all of your professional liability insurers and

Dwars. 
your policy 
aave you .ervoeg bre..n  sanctioned by the Medicare or

M8dic:id 
or by any other rederal agency? 
balth

Sa.. any or all of your privilege. at any 
care facility ever been, or are about to be,

1illi ted, supended, revoked, 
ref.ed rea_al, or

voluntarily surrendered?

repri8nd8 
Bave you ever been censured or 
by a

licensing board, bospita1 ..dieal bord/staff, or

any otber profesaional organi.ation?

10. aave you ever ben 
denied ...barahip or reneval 
thereof, or been .ubject to disciplinary proceedings

by any medical or profe.aional organi.ation?
 --.
---
. I 
: llasList all jurisdictions (past and present) where you  Yes 
gis  21, u. 
are or were r  ered under Title  s. Controll
ed Substance Act and provide your DEA controlled 
for each jurisdiction.
substance registration number 
. I f 
you have never been registered under this Act,
so state. 
egistrat 
be Has your r ion under this Act ever been

denied, suspended, revoked, refused renewal,

or vOluntarily surrendered?

c. Have you ever been charged with, or are currently

facing charges, hof a violation of this Act?

12. IIHave you ever been charged wi th, or are currently
fac ing charges of, a vi ola t ion 
of any State, Feder a 1, 
local, or any foreign government law (esg_, child

abuse, sexual assault, fraud, substance abuse

(alcohol/drugs), etc 
s )? " 
ficati
Signature, Certi on, and Release of Information 
You Must Sign this Application. Read

The Following Carefully Before You Sign.

I fully understand that a false statement to any 
question in this application, or the 
misrepresentation of information otherwise provided,
may constitute cause for denial/revocation of 
medical staff appointment and/or clinical privileges 
and may be punishable by fine or imprisonment (U. 
Code, Title 18, Section 1001). 
I certify that the statements/documents that I have 
true, 
made/provided in this application are 
complete, ana-c  ect to the best of my knowledge 
faith. 
and belief and are made in good 
I hereby authorize investigators, personnel staffing 
specialists, and other authorized employees of the 
Pederal government to consult with administrators 
and members of medical staffs of other hospitals or
insti tutions 
wi th which I have been associated and 
wi th others, including past and present malpractice 
carriers, who may have information bearing on my 
professional competence, character and ethical
quali fications.  . .
I fully understand that these Federal 
representatives may validate my professional 
credentials by consul tinq wi th th  Amer ican Medical 
Bords, 
Association, Federation of State Medical  and 
other nationally recognized bodies that maintain 
practitioners. 
automated data files on clinical care 
I hereby further consent to the inspection by the 
above mentioned Federal representatives of all records 
and documents, including medical records at other 
hospitals, that may be material to an evaluation of 
my professional qualifications for the position 
applied for. I hereby release from liability all 
representati ves of the Federal government for their
acts performed in good fai th and without malice in 
connection with evaluating my credentials and 
qualifications, and I hereby release fraa any 
liability any and all individuals and organizations 
informtion to these representatives in
who provide 
good fai tb and without malice concerning .Y 
professional copetence, ethics, character and 
other qualifications for the medical officer 
position and any applicable clinical privileges, and
informtion. 
I hereby consent to the release of such 
gnature  . Date  . .
1/ 
II 
APPENIX C

DESCRIPTION OF THE FEDERATION OF STATE MEDICAL 
BOARDS'

DISCIPLINARY DATA BAN

The FSMB was founded in 1912 and is the National Organization of 
Boards. Its 
Medical Licensing and Disciplinary  membership is 
comprised of the Medical boards of all the States, the District 
of Columbia, Guam, Puerto Rico, and the Virgin Islands and 
includes 11 of the 16 separate osteopathic boards in the United 
States. The 10 Canadian provincial medical licensing 
authori ties hold affiliate membership. 
ban 
The FSMB operate. a physician disciplinary data  (DDB) and 
disciplinar 
collects, .aintaina, and report.  actiona taken
again.t phy.ici&n re.ul ting from formal charge., by 1 
t. member 
governental 
boards and other  author1 tie.. 
The tyes of disciplinar  subseqently
actions collected and 
reported by FSMB involve the revocation, probation, suspension, 
voluntar surender of a 
denial, re.triction, or  medical license
and/or narcotic permt, 
iJ.ed  HHS Medicare/Medicaid sanctiolU,
sanctiona  BCF 
by DOD,  sanctiona, allegationa of 
cheating on the Fedearnat aio n Licenaing Bx8lnat10n, which i8 now 
uaed by all State.  nU8ber of other juri.dictions, .a11 
fraud and inatance. of repr:1d or ad8ni.hlent. (See Ezibi 
1: A 
for a comlete  . of disciplinar actions 
list of the 
ma.ntained by FSMB. 
Acce.. to .
the infor8ation aaintained in the DDS fall. 
.ajor categories - full acce.. and l  ted acce... Allint: o  physician
licensin an/or diaciplina  an 
1:tb oarda in th U.S..  Canada that 
.ber. or  report action to. the Pederation 
afreo Perde ratiionn c
 lu.ion in the DDS, th AH, an the A8rican O.teopa'tc
As.ociation (  oZ'tion proide for attibuted 
che..  Departu.a ea) nha ve full 
acce.d. ia.tc niop lin,  Pedral an State  agencies
with 
inve.tigative, or 1- enforc_nt 
respnsibilitie. related  cal care al80 have full access 
ne1: 1: 
but 111:  iated fee. Lil ted acce.. service. are
proided, paC a D
  a netiated fe8e7 bta-i)s,,  to hospitals (invidual,
grup, OJ: 8i1D  8D  tion  health an profe..ional
IliIanbitl8itfy8    U.1U  cariers, Mlected phician grup. (health
or8DaaUon: State, regionl an local 1npendent
), an 
practice 888Oiation, 8tC..  State an coty 88cal
8Oietie.  . ...
\" 
3. -

Exibi t A:  Action Cod..

100 LICESE 
REVOKED
101 
ALCOHOLISM
102 
INCOMPETENCE/MALPRACTICE/NEGLIGENCE
103 
NARCOTIC VIeLATIONS
104 
FELONY
105 
FRAUD
110 
UNROFESSIONAL CONDUCT
120 MEAL 
DISORDER
130 
ALLOWING UNICENSED PERSON TO PRACTICE 
140 VOLUNARY SURRENER OF LICENSE
150 DISCIPLINARY ACTION TAK IN ANOTER STATE 
180 OTHR REAON - NOT CLSIFIED 
200 
CODS/PROBATION 
200 PROBATION FOR MEICA LICESES (ALONE OR AFTER STAY qF
OTER ACTION)
201 
ALCOHOLISM
202 
INCOMETENCE/MAPRACTICE/NEGLIGENCE
203 NACOIC VIOLATIONS 
204 FEONY

205 FRUD

210 
UNROFESSIONAL CONDUCT
220 
MBAL 
DISORDER
230 
ALLOWING UNICESED PERSON TOA PRNACRTIC E
250 DISCIPLINAY ACTION TAK IN  STATE
260 
PROBATION MODIFIED
270 
VIOLATED PROBATION
HAON - NO CLSIFIED
280 
300 COOS/SUPENION

300 LICBB 
SUSPENED 
301 ALCOLISM

ft/MPRACTICE/NBIG8CB
..co
302 
IC VIOLATION
33030& 
..aon8ION 
305  Ar 
CONDUCT
310 
AL DISORDD
3320 30 
UNICBSED PDSON If PlCTIC8 
TAK 
350 DISCIPLINA ACION  STAft
O' UAN 
IN 
NO CLSIPIBD
380 
.a CODB/MISCBLAS

400 LICZB ItTORB OR RBINSTA'l

un.8 
401. 1 Prb.  8d - 188Ued 
iOf o pr.c  ic8 
licen8 
401. 6 R88  or8d or r8ift  8d bu  ill Of probation  . -
tt "

t I 
401.	 a.stored or reinstated but must limit practice
o certain  or institutlon( s) 
area( s) 
her restoration/reinstatement, not listed
401. 8 
402  REINSTATEM DENIED 
403  LICESE BY RECIPROCITY DENIED

404  ADMITTANCE TO EXINATION DENIED

405  NARCOTIC PERMITS 
405.	 Permission given to apply for permit
405. 2. Direc ed not to apply for permit 
405. 3 	Reques  o and/or voluntarily surrendered
ed 
permi t

405.	 Permit no longer needed as per agreement with
board 
P.rmt 
405.	 denied 
405 e  o apply for .  ed schedules 
P.rmi..ion given 
406 REPRIMA OR ADMONISHM
407 
DUPLICATE LICESE ISSUE 
401. 1 Chg. of nae 
401.	 Lic.ns. . olen or lost
408 
ACCSATPIOND DIMSMIS SED
409 DENIED  LICESB - ISSUE TERAY LICESE
410 OTR MISCELLAOUS ACTION - NO CLSIFIED
(stipula  ord.r)
ion or coft.n 
411 
ALLEGATIONS OP CHTING 
411.  aken bu  grade. not given out
411. 21 ba a 'Bjected fre baa 
412 LICESB DENIED 
ial.
412.	
Fraudulent 
412.	 8Cc.p  .ble evid.nc. of
Pailed to sub8 
 tra1ng
postgraduate 
412.	 Falsified Applica ion 
4 Ot.r 
listed
412. 
414 RES'l 
POR 'lIMATION OP PROBATION DENIED
490 ACCSATION FILBD - COAC MEICA 
500 CODB/MISCBLA 
MISCBS 
500 
513 D.  S. M8ICA SAIONS (SSA:  SBC 1128/1862 (d)
1160 )
88luaion
513.	
R3. 2 SU8:1on 
3 .i 
113. aval 
..tD8
513.	
514 1A10M 
O. MILI'1AI SDVIC8 
alcol 
lDt88rat. ua of 
514.	
v:olat:l0f/ua
514. 2 NarU,c  prol
514.	 B8al1: r.lated 
1:en./nelig8.
514.	
not listed
514. 
PR 
515 
DISMISSED  MILITAR SBaRVlIcCoSl  
of 
515.	 Int.-ra1:. us. 
515.	 Narcotic v:lola  :l0f/U8.
B811: related probl.. 
515.	 j" 
lJ" '\\ 
515.  Incompetence/Negligence 
her not listed 
515. 5 
516  PCOSRTAEL DINSEPENCTTIOIN ASELRVSIC)E (MAIL' FRAUD  FRAUDULENT
517  E. C. F . M. G. (FRAUDULENT CREDENTIALS) 
Cot