CurrentBaylor Scott & White Health PlanPolicy SWHP.PNO.009.P

Confidentiality of Credentialing Files

Governs confidentiality, access, security, and practitioner rights related to SWHP/ICSW practitioner credentialing and re-credentialing files; applies to Provider Network Operations and all lines of business.

Policy Summary

PayerBaylor Scott & White Health Plan

PolicyConfidentiality of Credentialing Files

Policy CodePolicy SWHP.PNO.009.P

Change TypeNo material changes

Effective DateApr 14, 2021

Next Review DateFeb 24, 2021

Key ActionRefer external requests (e.g., subpoenas) to a Medical Director or Executive Director.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

All Linesapplicability

Lockedphysical security

Password protectedelectronic security

Review/Copypractitioner access

Confidentiality statementrequired agreement

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Confidentiality, Access, and Security Criteria

Operational requirements and rights regarding credentialing file confidentiality, access, and security.

Credentialing data must be maintained in accordance with federal and state regulations and stored in a secure environment with strict controlled access.

Based on SWHP/ICSW policy for credentialing/re-credentialing data.

ALL of the following

Each committee member signs/commits to the Credentials Committee Confidentiality Statement (SWHP.PNO.009.A1).

Credentialing delegates have access to credentialing information/files only as specified in their delegation agreements.

Delegate access governed by delegation agreements.

Practitioners have the right to review or copy any documents they submitted (for example: initial application, application for credentialing/re-credentialing, delineation of privileges, or correspondence to/from the practitioner).

Practitioner access to their own submitted documents.

Physical credentialing files are kept in locked cabinets except when credentialing personnel are physically present to monitor access; files are the property of SWHP/ICSW and may not be removed except for peer review or regulatory/accrediting surveys.

Physical security and ownership restrictions.

Electronic credentialing information is password protected and stored on a secure SWHP/ICSW network drive accessible only to credentialing staff.

Electronic security measures for credentialing files.

Requests for credentialing information from outside agencies, subpoenas, or any person other than authorized parties are referred to a Medical Director or Executive Director of SWHP/ICSW.

External request handling procedure.

SWHP.PNO.009.A1 - Credentials Committee Confidentiality Statement is an attachment and required for committee members.

Attachment requirement for committee members.

Access and External Request Handling

Documentation Required

Access limited to official business; refer external requests to medical/executive director

SWHP/ICSW Credentials Committee members and authorized credentialing delegates may access credentialing files only for official credentialing business per delegation agreements; committee members must commit to confidentiality as described in the Credentials Committee Confidentiality Statement. External requests for information (including subpoenas or requests from outside agencies or persons not authorized) must be referred to a Medical Director or Executive Director of SWHP/ICSW.

Committee access limited to official Credentials Committee business; members must sign/commit to the SWHP.PNO.009.A1 Confidentiality Statement.
Delegates’ access is limited to the scope specified in each delegation agreement.
All external requests, subpoenas, or requests from unauthorized persons are referred to a Medical Director or Executive Director.

Key Definitions

inv-03: Credentialing files

DefinitionCredentialing files: data/information gathered and/or documented by Scott & White Health Plan (SWHP)/Insurance Company of Scott & White (ICSW) or a credentialing delegate related to practitioner credentialing and re-credentialing.

Storage ResponsibilityFiles are maintained by the credentialing delegate and/or SWHP/ICSW in a secure environment with strict controlled access.

Regulatory RequirementConfidentiality of credentialing data is maintained in accordance with federal and state regulations.

Access LimitationAccess is strictly controlled and limited to authorized personnel and delegates per policy and delegation agreements.

inv-04: Credentials Committee Confidentiality Statement

DefinitionCredentials Committee Confidentiality Statement: a signed agreement by committee members to maintain confidentiality of patient-identifying information, provider qualification information, and sensitive business information.

Permitted UseCommittee members will use confidential information only for the official business of the Credentials Committee.

Non‑disclosure and Legal ExceptionsCommittee members will not reveal confidential information except as required by applicable law.

Secure HandlingWhen in possession of such documentation, members will keep the documentation in a secure and locked place and provide signature and date on the statement.