Understanding the National Practitioner Data Bank (NPDB) & Reporting Disciplinary Actions for EMS Clinicians

The National Practitioner Data Bank (NPDB) is a federal repository established to enhance the quality of healthcare, improve patient safety, and combat fraud and abuse in the healthcare system. It serves as a centralized database of information regarding the credentials and conduct of healthcare professionals, including EMS clinicians.

What is the NPDB?

The NPDB was created by Congress as part of the Health Care Quality Improvement Act of 1986. Its primary purpose is to collect and release information related to the professional competence and conduct of healthcare practitioners. This includes:

• Medical malpractice payments
• Adverse licensure actions
• Adverse clinical privileges actions
• Adverse professional society membership actions
• Certain other adjudicated actions or decisions

Federal Requirement for All Licensed Healthcare Professionals

Under federal regulations, all licensed healthcare professionals, including Emergency Medical Services (EMS) clinicians, must be reported to the National Practitioner Data Bank (NPDB). This requirement is detailed in Title 45 of the Code of Federal Regulations (CFR), Part 60, which governs the operation and use of the NPDB. The NPDB operates by the following laws:

• Title IV of the Health Care Quality Improvement Act of 1986 (HCQIA), Public Law 99-660
• Section 1921 of the Social Security Act
• Section 1128E of the Social Security Act

For more details, you can refer to the Electronic Code of Federal Regulations (eCFR) or the NPDB Guidebook.

EMS Clinicians and the NPDB

EMS clinicians are integral to the healthcare system, often serving as the first point of contact for patients in emergency situations. As licensed healthcare providers, they are subject to the same reporting requirements as other medical professionals. This includes the mandatory reporting of:

• Disciplinary actions
• Loss of licensure or certification
• Suspension or revocation of clinical privileges
• Any other actions that affect their professional standing

Any medical professional, including EMS Clinicians, can perform a self-query of the NPDB to view their record (if a record exists).  The NPDB is maintainned by the U.S. Department of Health & Human Services and can be accessed here: NPDB Self-Query. Information on how to dispute an NPDB report is available on the HRSA/NPDB website: https://www.npdb.hrsa.gov/pract/howToDisputeAReport.jsp

The EMS Compact and the National EMS Coordinated Database (NEMSCD)

The EMS Compact law requires disciplinary actions against EMS clinicians to be reported to the National EMS Coordinated Database (NEMSCD). The NEMSCD is designed to facilitate the sharing of disciplinary action information among member states, ensuring that EMS clinicians who move across state lines are held to consistent standards.

The NEMSCD utilizes the same reporting format as the NPDB, ensuring uniformity and consistency in the information collected and shared. This alignment helps streamline the reporting process and ensures that disciplinary actions are accurately and efficiently communicated across state lines.

Importance of Reporting

Reporting to the NPDB and NEMSCD plays a critical role in maintaining high standards of practice within the EMS profession. It helps protect the public by ensuring that EMS clinicians who have had disciplinary actions taken against them are tracked and monitored, preventing them from evading accountability by moving to different states or regions.

By adhering to these reporting requirements, EMS agencies and clinicians contribute to the overall integrity and trustworthiness of the healthcare system, ensuring that patient care remains safe, effective, and of the highest quality.

Resources for State EMS Officials

All disciplinary actions must include a factual narrarative, have one or more Action Code(s) and one or more Basis for Action code(s).

Factual Narrative

 

Action & Basis Codes

A quick reference of these code(s) is below. The recommended practice is to avoid the “Other” fields. By way of example, the notice in a disciplinary action letter may read: As required under Sections… the following codes shall be reported to the National Practitioner Data Bank: License Action Codes 1125 (Probation of License), Code 1310 (Revocation of Multi-State Licensure Privilege); and the Basis For Action Code(s) H4 (Inappropriate or Unauthorized Administration of a Medication or Sedation) and F6 (Substandard or Inadequate Care).

Step 1 - What Action Was Taken by the State

Step 2 - Identify One or More (Max 5) 'Basis for Action' Codes

Licensure - Revisions to Actions (No Basis for Action Codes Required)

Licensure - Revisions to Multi-State Privilege Actions (No Basis for Action Codes Required)

Disclaimer: The information provided on this webpage is for educational and informational purposes only. State EMS Officials should refer to the official Federal Regulations and EMS Compact requirements for complete and accurate details regarding the reporting of disciplinary actions. This webpage does not constitute legal advice and should not be relied upon as such. For specific guidance, please consult the relevant regulatory and legal resources.