Health Law Matters

New Requirements to Report to the National Practitioner Data Bank

Requirements to Report

In October of 2018, the National Practitioner Data Bank (NPDB) published an updated NPDB Guidebook that revises the requirements for reporting changes in a practitioner’s clinical privileges, licensure, and malpractice. 

Notable revisions to the Guidebook include the fact that each of the following situations is now identified as a reportable change in a practitioner’s status:

  • “Acceptance of the surrender of clinical privileges or any restriction of such privileges… while under investigation.”
  • A leave of absence while under investigation that restricts privileges.
  • A reappointment review in which officials at the reappointing hospital have specific concerns about the practitioner’s competence based on the number or severity of medical malpractice cases.
  • A Quality Improvement Plan that:
    1. is the result of a provisional review action regarding competence or quality,
    2. restricts privileges, and
    3. remains in place after 30 days.
  • A requirement that a surgeon operates only with a qualified first assistant if the requirement is:
    1. imposed on a specific surgeon,
    2. a professional review action about competence and conduct, and
    3. in place after 30 days;
  • A restriction that is in effect for more than 30 days, regardless of the stated length of the restriction. (For example, a restriction on the surgeon’s next 5 bowel surgeries which ends up lasting more than 30 days.)
  • An adverse action that is the result of a private agreement between a provider and state agency.
  • An enforceable agreement signed by a board that an impaired practitioner will not practice, is in “inactive status,” or other voluntary agreement not to practice while under investigation or in exchange for not conducting an investigation.
  • Payment by a sole shareholder professional corporation relating to conduct by the shareholder physician or identified staff.

The October 2018 NPDB Guidebook is available at

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Thomas D. Anthony is the former chair of FBT's Health Care Industry Team. He focuses on counseling health care entities on corporate transactions, regulatory compliance and joint ventures.