What should I be aware of when renewing my Nevada professional license through my employer’s credentialer or a credentialing agency?

• You are ultimately responsible for the information contained in your initial or renewal application.

It has become extremely common in the last several years for providers renewing a medical license or other credential to be assisted by a credentialer within their organization or by a third-party credentialing agency.  These individuals/agencies can help the renewal process move more expeditiously and allow providers to focus on their professional practices, rather than what may be considered administrative tasks.  However, errors in any application will be deemed the responsibility of the provider regardless of whether a credentialer assisted in the submission of the application.  For instance, if a provider was investigated or disciplined by another state licensing board during the period of time addressed in the renewal application, and that information is not known by the credentialer, and thus not disclosed, the provider may find themselves subject to disciplinary or other action by the renewing agency.

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Don’t assume your credentialer is aware of everything that has occurred in the last renewal period.  If you have any information which may need to be disclosed, be sure to review the application and any supporting materials prior to the application being submitted.  Additionally, it is highly recommended that you do not rely solely on the credentialer to draft the explanation to questions requiring an affirmative answer.  Disclosures must be carefully crafted in most circumstances and should be drafted by you or someone familiar with the process and who understands your individual disclosures. 

 

• Don’t assume your credentialer is familiar with the requirements in every state.

More and more frequently credentialers are located outside of the state where an individual may be applying for a license or credential often due to corporate ownership of more medical, mental health, veterinary, and dental practices, just as examples, or simply because a third-party credentialing agency is used based in a state different from the practitioner.    While this may not be an issue in most application submissions, do not rely on the credentialer to be aware of all requirements within a particular state for you to practice your profession. For instance, any provider that may prescribe a controlled substance including a physician, dentist, veterinarian, etc., must obtain a controlled substance registration from the Nevada State Board of Pharmacy in addition to a DEA registration; information that may not be conveyed to you by an out-of-state credentialer.  Be sure to always check all requirements pertaining to your specific license before commencing practice.

 

• Read every question carefully.

License applications and other credentialing applications frequently contain similar questions.  While these questions may often appear identical, it is imperative that each question be reviewed carefully.  Questions often contain small differences that may require information to be disclosed on one application that is not required on another application.  For example, an application may ask if an individual has ever been arrested, charged with, or convicted of any criminal offence while another application may ask if an individual has been convicted of a felony.  These questions would be answered very differently if the individual was arrested for a misdemeanor DUI, which was ultimately dismissed and no conviction entered.  The second application could clearly be answered with a “no”, but the first application would require a yes “answer” and typically some type of explanation.  Don’t make assumptions about what information any particular question is asking for; failing to answer appropriately could result in disciplinary action or denial of an application. 

 

• When in doubt, disclose and explain.

As discussed above, the failure to disclose required information can result in significant consequences. The failure to disclose information is frequently viewed by the entity issuing the license or credential as misrepresentation or deceitful conduct and creates more issues than if the underlying information was disclosed and explained.  Occasionally information is not disclosed because the individual, often erroneously, believes the information to be confidential or otherwise not discoverable by the licensing entity.  Frequently, the failure to disclose information is due to differences in language used by boards or credentialing entities.  For instance, a question may ask about sanctions rather than discipline, or whether a provider has been reprimanded rather than censured.  Many state licensing boards and credentialing entities use different terminology for the same thing; don’t assume that because you were censured by another state board and the question asks if you’ve been reprimanded that you don’t need to disclose the censure.  It is safer to disclose and explain than risk failing to disclose.   Always review the information being submitted to your licensing board by a credentialer on your behalf.  If you are in doubt as to whether something should be disclosed, you should reach out to an attorney familiar with professional licensing for further guidance.