"Triple Lock" - Changes in EMS Regulatory Terminology
In November 2013, Council adopted revised terminology in keeping with regulatory best practice internationally. The terms; credentialing, licencing and privileging will be incorporated into the PHECC practice or context for practice regime. This generates a "triple lock" situation where all three requirements must be in place in order to legally practice.
Patient safety in healthcare practice is supported by establishing a practice regime which promotes;
- educated and competent professional practitioners,
- consistent, appropriate and standardised criteria among service providers and
- regulated or controlled scopes of practice for practitioners.
It is important to clarify the regulatory terminology used as some of the terms mentioned are misused or used interchangeably depending on the healthcare location, situation or profession involved. PHECC define and use these three terms as follows.
Credentialing is the process of assessing and confirming the qualifications of a health care practitioner. It is the systematic method of reviewing and ensuring that registered practitioners possess the education, training, experience and skill to fulfil the requirements of their position.
The process involves collecting and verifying information about a practitioner, assessing and interpreting the information, and making decisions about that practitioner. Used generally, credentialing is a universal term, which incorporates practice licensure, certification, accreditation, recognition, and registration.
Credentials are a standards or quality mark of achievement. They inform service providers, employers, and patients what to expect from a ‘‘credentialed’’/registered PHECC practitioner. Credentials must be periodically renewed as a means of assuring continued quality and they may be withdrawn when standards of competence or behaviour are no longer met.
Licencing is a process that approves organisations to use and implement specific Clinical Practice Guidelines (CPGs) when providing pre-hospital emergency care. PHECC, as the competent authority and statutory agency, assess and recognise service providers who meet prescribed detailed requirements necessary for the implementation of CPGs.
Council prepare CPGs and make them available to pre-hospital emergency care service providers as Council consider appropriate. Thus service providers who meet with specific PHECC requirements are approved/licenced to implement PHECC CPGs at an appropriate level.
The approval or recognition process requirements typically include a combination of staff vetting, language competency, education and training to maintain currency with CPGs and other continuous professional competency (CPC) requirements. In addition organisations must demonstrate compliance with clinical audit, medical direction and adverse clinical incident reporting systems along with evidence of appropriate vehicles and relevant equipment.
Service providers may not practice in Ireland without a PHECC licence because access and authority to administer medicinal products are directly linked to CPG approval.
Privileging is the process by which licenced service providers empower practitioners to provide specific services to their patients. Privileging defines the scope of practice or permitted interventions and CPGs that the health professional may engage in while providing care.
Privileges are granted for the practitioner to provide specific care and services in an organisation within well-defined limits. The licenced service provider privileges practitioners, operating on their behalf, to implement PHECC CPGs in accordance with each practitioner’s current competency and CPG status.
The delineation of clinical privileges is both individual and status specific for each service provider for whom the practitioner is operating. (A practitioner may have 2 differing scopes of practice (privileges) depending on the level of CPG approval which the service provider has been granted. It would not be uncommon for an AP working for a statutory organisation to be limited to a P scope of practice when with a voluntary organisation.)
Clinical privileges should be revised in line with a practitioner’s competency and CPG status.