Q: Are non-employed physicians and other licensed independent practitioners included in the health requirements specified in IC.02.03.01 EPs 1, 2 and 3? Do we need to screen them for TB infection as well as immunity to other diseases?
A: For IC.02.03.01 EP 1, the standard requires that screening "is available". For employees, and others to whom the HR standards apply, health screenings are a requirement under HR.01.02.05 EP 5 (HAP and CAH). 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.06.01.05 EP 6 (HAP and CAH).
For EP 2, treatment or referral is initiated if the organization becomes aware of any individual, including non- employed physicians and other licensed independent practitioners, who “have, or are suspected of having, an infectious disease that puts others at risk”.
For EP 3, treatment or referral is initiated if the organization becomes aware of any individual, including non- employed physicians and other licensed independent practitioners, who “have been occupationally exposed to an infectious disease”. Active surveillance is not required for either EP 2 or 3 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.01.05.01 EP 1 requires the use of "evidence-based national guidelines or, in the absence of such guidelines, expert consensus".
- 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.