Surgical Center Credentialing vs. Hospital Privileges: Key Differences

Practice Type Guide

Two Systems, Different Requirements

There are just under 10,000 ASCs in the U.S., and each one is required to have some type of credentialing and privileging process in place. While credentialing itself is not unique to ASCs, the ASC setting requires specific procedures to match the environment's unique demands.

For surgeons and proceduralists working in both hospital and ambulatory settings, understanding the differences in credentialing requirements is essential for maintaining privileges across all practice sites.

Understanding the Key Distinction

Credentialing vs. Privileging

First, clarify the terminology:

Both hospitals and ASCs perform credentialing. Both grant privileges. But the processes, requirements, and governing bodies differ.

Regulatory Framework Differences

Hospital Credentialing

Hospitals typically operate under:

• CMS Conditions of Participation
• Joint Commission accreditation standards
• State hospital licensing requirements
• Medical staff bylaws

ASC Credentialing

Some states are governed by state licensure, others require third party accreditation, and some must comply with both. In all 50 states, ASCs must meet the Centers for Medicare and Medicaid Services' (CMS) Conditions for Coverage (CfCs) to receive Medicare payment.

ASC accreditation options include:

• Accreditation Association for Ambulatory Healthcare (AAAHC)
• The Joint Commission (ASC-specific standards)
• State-specific requirements

Joint Commission is designated by CMS as an approved accreditor for ASCs seeking Medicare initial certification, and can provide accreditation and Medicare certification simultaneously through its survey process.

The Independent Credentialing Requirement

ASCs Cannot Rely on Hospital Credentials

This is the most important difference: ASCs are not permitted to grant privileges based on the fact that a provider might have privileges somewhere else. All ASCs must make their own decisions and these decisions need to be based upon data that they have either collected themselves or have received from a CVO (credentials verification organization).

Even if a surgeon has full privileges at a major hospital across the street, the ASC must:

• Conduct its own credentialing verification
• Maintain its own credentialing files
• Make independent privileging decisions

Hospital-Owned vs. Freestanding ASCs

The relationship between hospital and ASC credentialing depends on the ownership structure:

On-License (Hospital-Owned, Under Hospital License):
Usually, the on-license facilities are covered by existing hospital privileges, modified for appropriate procedures being done in the ambulatory environment. Practitioners with hospital privileges who work primarily at the off-site clinic will be required to undergo the same ongoing competency assessment as those practitioners on the medical staff of the hospital.

Off-License (Freestanding ASCs):
Off-license facilities have to have their own credentialing body and files. Although the hospital may be governed by Joint Commission and CMS credentialing guidelines, the off-site facility may do its own credentialing and privileging and use different guidelines (such as NCQA guidelines).

Scope and Scale Differences

Hospital Privileging

• Broader scope: Full range of medical and surgical procedures
• Emergency capabilities: Includes emergency and trauma privileges
• Complex cases: High-acuity patients, comorbidities
• 24/7 coverage: Call schedules, emergency availability
• Multiple departments: OR, ICU, floor care

ASC Privileging

Unlike hospitals, ASCs generally operate on a smaller scale, focusing on efficiency and rapid turnover.

• Focused scope: Outpatient procedures only
• Patient selection: Lower-acuity patients
• Same-day discharge: No overnight stays
• Efficiency focus: High-volume, predictable procedures
• Limited emergency capability: Transfer arrangements for complications

Privilege Delineation

ASC privileges are often more narrowly defined than hospital privileges:

Timeline Differences

Hospital Privileging Timeline

• Initial application: 60-120 days typical
• Reappointment: Every 2 years (3 years in some states)
• Medical executive committee and board approval often required
• More extensive peer review process

ASC Privileging Timeline

It takes on average 60 to 90 days for surgery centers to collect all credentialing material required.

• Initial application: 60-90 days typical
• Reappointment: Every 2 years (except Illinois: 3 years)
• Often simpler governance structure
• May have expedited processes for urgent needs

Temporary Privileges

ASCs can grant temporary permission for surgeons to perform cases without all credentials in place, but it's prudent to conduct a background check on surgeons first. Hospitals also offer temporary privileges but typically with more restrictions.

Documentation Requirements Comparison

Common Requirements (Both Settings)

• Medical license verification
• DEA registration
• Board certification
• Malpractice insurance
• Education/training verification
• Work history
• Professional references
• NPDB query
• Background check

Additional Hospital Requirements (Typical)

• More extensive peer references
• Case log documentation
• CME documentation
• Health clearance (physicals, immunizations)
• OPPE/FPPE data from other facilities

ASC-Specific Considerations

• Procedure-specific volume/competency
• Appropriateness for outpatient setting
• Transfer agreement acknowledgment
• Emergency protocol familiarity

Ongoing Requirements

Hospital OPPE/FPPE

Hospitals are required to conduct:

• FPPE (Focused Professional Practice Evaluation): For new privileges or new practitioners
• OPPE (Ongoing Professional Practice Evaluation): Continuous monitoring of all privileged practitioners

ASC Competency Assessment

ASCs must also conduct ongoing competency assessment, but the methods and frequency may differ from hospital requirements. Providers must be credentialed and privileged upon hire and every two years after that.

What Happens When You Have Both

Maintaining Dual Privileges

Many surgeons hold privileges at both hospitals and ASCs. This requires:

• Separate applications: Each facility has its own process
• Separate files: Each facility maintains independent records
• Separate renewals: Different reappointment cycles
• Consistent information: Discrepancies create problems

Streamlining with CVOs

Credentials Verification Organizations (CVOs) can help by:

• Performing primary source verification once
• Providing verified credentials to multiple facilities
• Maintaining updated files
• Reducing duplicative work

However, each facility still makes its own privileging decisions based on the verified credentials.

Payer Implications

Hospital-Based vs. ASC Billing

Payer credentialing for hospitals and ASCs may require separate enrollments:

• Medicare requires separate enrollment for ASC billing
• Commercial payers may have separate ASC panels
• Rates differ between hospital outpatient and ASC settings

Privilege Requirements for Payer Enrollment

Some payers require proof of privileges at the facility where services will be performed. ASC enrollment may require documentation of ASC-specific privileges.

Best Practices for Multi-Facility Surgeons

Maintain Organized Records

• Keep copies of all applications and approvals
• Track expiration dates for each facility
• Maintain consistent CV across all applications
• Update all facilities when information changes

Plan Ahead for Renewals

• Hospital and ASC renewals may not align
• Create a calendar of all credentialing deadlines
• Start renewal processes early

Communicate Changes Proactively

• License renewals, address changes, malpractice updates
• Notify all facilities where you hold privileges
• Don't wait for them to discover discrepancies

Conclusion

Hospital privileges and ASC credentialing serve the same fundamental purpose—ensuring qualified providers perform appropriate procedures—but operate under different regulatory frameworks with different requirements. The most important difference is that ASCs cannot rely on hospital credentials and must make independent credentialing and privileging decisions.

For surgeons working in both settings, this means maintaining separate relationships with each facility's credentialing process, understanding the specific requirements of each, and staying organized across multiple renewal cycles.

Key Takeaways

• ASCs must credential independently: Cannot rely on hospital privileges
• Different regulatory bodies: CMS CfCs, AAAHC, Joint Commission for ASCs
• Narrower privilege scope at ASCs: Procedure-specific, outpatient only
• Similar timelines: 60-90 days for ASC, 60-120 days for hospital
• Reappointment every 2 years: For both settings (with exceptions)
• Separate payer enrollment: May need ASC-specific enrollment

References

[1]: HealthStream - Facts ASCs Need to Know About Privileging https://www.healthstream.com/resource/white-papers/facts-all-ambulatory-surgery-centers-need-to-know-about-privileging

[2]: MedTrainer - ASC Credentialing https://medtrainer.com/blog/asc-credentialing/

[3]: Joint Commission - Accreditation for ASCs https://www.jointcommission.org/en-us/accreditation/ambulatory-health-care/ambulatory-surgery-centers

[4]: CMS - Ambulatory Surgical Centers https://www.cms.gov/medicare/health-safety-standards/certification-compliance/ambulatory-surgery-centers