Q: Are non-employed physicians and other licensed independent practitioners included in the health requirements specified in IC.4.10 EPs 5, 6 & 7? Do we need to screen them for TB infection as well as immunity to other diseases?
A: For IC.4.10 EP 5, the standard requires that screening "is available". For employees, and others to whom the HR standards apply, health screenings are a requirement under HR.1.20 EP 7. For non-employed physicians and other licensed independent practitioners, screenings must be made available, but each organization may decide whether these screenings are mandatory. The health status of an applicant for medical staff privileges is also addressed under MS.4.20 EP 6.
For EP 6, referral is initiated if the organization becomes aware of any individual, including non- employed physicians and other licensed independent practitioners, "who are identified as potentially having an infectious disease or risk of infectious disease that may put the population they serve at risk".
For EP 7, referral is initiated if the organization becomes aware of any individual, including non- employed physicians and other licensed independent practitioners, who "have been exposed to infectious disease(s)" or who have been "occupationally exposed". Active surveillance is not required for either EP 6 or 7 action is needed only if the organization becomes aware of such an exposure.
When making a decision as to how to address these issues, organizations are encouraged to consider the following factors:
- Physicians are specifically included by the CDC in the documents entitled "Immunization of Health-Care Workers" and "Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005". IC.4.10 EP 1 requires that "Interventions are designed to incorporate relevant guidelines* for infection prevention and control activities. * Examples of guidelines include those offered by the CDC, Healthcare Infection Control Practices Advisory Committee (HICPAC), and National Quality Forum (NQF)."
- Many states require such screenings for all healthcare workers, including physicians and licensed independent practitioners.
- Biologically, all persons providing services in healthcare organizations are equally capable of transmitting disease.
- Legal and ethical considerations exist related to potential outbreak situations.