NPDB Insights - January 2025

Is It Reportable?

A clinic terminates its contract to participate in a federal health care program for business-related reasons. No investigation or other action was pending. Should this action be reported to the NPDB?

No. Federal licensing and certification agencies should only report voluntary surrenders (including voluntary terminations) of a license, certification agreement, or contract for participation in a government health care program for reasons specified in the NPDB regulations. This action should not be reported if the clinic did not voluntarily terminate its contract while under investigation, in exchange for a decision by the licensing or certification agency to cease an investigation or similar proceeding, in return for not conducting an investigation or proceeding, or in lieu of a disciplinary action.

Want More 'Is It Reportable?' Visit Our Policy Corner

We created the Policy Corner in response to your questions about the laws and regulations that govern the NPDB. The Policy Corner can help you understand the NPDB’s reporting and querying policies.

In addition to more 'Is It Reportable?' scenarios, the Policy Corner also contains the following resources:

• guidance on when query responses can be shared within a health care system
• an “Ask it Now!” submission form for policy answers from the NPDB team
• links to other important resources such as the NPDB Guidebook and statutes and regulations.

The Policy Corner is updated as needed, so you will always have access to the latest information.

Dear NPDB

When is proctoring reportable?

Whether you should report the assignment of a proctor (also called preceptor, mentor, monitor, etc.) depends on several factors. If you should report the assignment of a proctor, consider the impact of the proctor in limiting the practitioner's privileges. That is, does the assignment of the proctor restrict a practitioner's ability to practice independently? You should report proctoring if all the following are true:

• It is a result of a professional review action related to professional competence or conduct,
• It is a limitation on the practitioner’s privileges, and
• It is in effect for more than 30 days.

If, as the result of a professional review action, your organization restricts a practitioner’s privileges for more than 30 days, you must report it. A restriction is any action that limits a practitioner’s ability to practice independently.

For example, these are all examples of proctoring that limits a practitioner’s ability to practice independently:

• A proctor must approve, and can deny, the practitioner's ability to perform a procedure,
• A proctor provides concurrent consultation (the practitioner and the proctor must agree on the procedure) before administering care, or
• A proctor must be physically present before the practitioner may administer care.

Note: The above is not a complete list.

When is proctoring not reportable?

You should not report proctoring that

• does not restrict clinical privileges (for example, if the proctor is not required to be present for, or approve, procedures)
• lasts 30 or fewer days
• is routine (for example, if your organization requires the proctoring of all new practitioners)

However, if it is determined that the period of proctoring needs to be extended, or the number of proctored procedures needs to be increased for a particular practitioner – when this is not required for all new practitioners – then this is no longer considered routine. At this point, the proctoring is focused on the individual practitioner and must be reported if it is a restriction and lasts longer than 30 days.

Still have questions about proctoring? Visit Chapter E: Proctors in the NPDB Guidebook for more information.