Submitting Reports to the NPDB

Report Formats

The NPDB uses three report formats to capture the necessary information for report submissions. These report formats are:

• Medical Malpractice Payment Report (MMPR), for reporting medical malpractice payments
• Judgment or Conviction Report, for reporting health care-related criminal convictions and civil judgments in federal or state court
• Adverse Action Report, for reporting all other actions required to be submitted to the NPDB

All fields required by specific report formats must be completed successfully before a report can be generated. If an entity does not have all the required information, the entity is responsible for obtaining the information so that the entity can comply with its reporting requirements. An entity's lack of mandatory information does not relieve the entity of its reporting requirements.

The NPDB recommends that each reporting entity review the report form fields and make an effort to routinely collect information on health care practitioners, entities, providers, and suppliers (as appropriate) before there is a reason to submit a report (e.g., during the application process for a license or clinical privileges). In submitting a report, all required information must be completed properly.

For help with submitting a report, contact the NPDB Customer Service Center.

Types of Reports

Reporting entities are responsible for the accuracy of information they report to the NPDB and for keeping information reported to the NPDB up to date. Reports submitted to the NPDB are permanently maintained unless corrected or voided by the reporting entity or by the NPDB through the Dispute Resolution process. The following report types facilitate accurate reporting.

Initial Report

The first report of a medical malpractice payment, adverse action, or judgment or conviction submitted to and processed by the NPDB is considered the Initial Report. When the NPDB processes an Initial Report, the NPDB provides the reporting entity with a copy of the report. The NPDB also sends a notification to the subject of the report. The reporting entity and the subject of the report should review the report information to ensure that it is accurate. For certain types of actions, reporters also must provide a copy of the report to the appropriate state licensing board or state licensing or certification authority.

Correction Report

A Correction Report corrects an error or omission in a previously submitted report by replacing it. The reporting entity must submit a Correction Report as soon as possible after the discovery of an error or omission in a report. The reporting entity may submit a Correction Report as often as necessary.

When the NPDB processes a Correction Report, the NPDB provides the reporting entity with a copy of the Correction Report. In addition, the NPDB sends a notification to the subject of the report and a copy to all queriers who received the previous version of the report within the past 3 years. The reporting entity and the subject of the report should review the report information to ensure that it is accurate, and past queriers should note the changed report. For certain types of actions, reporters must provide a copy of the processed report to the appropriate state licensing board or state licensing or certification authority.

Example: A hospital reports a clinical privileges action to the NPDB, generating an Initial Report. Upon receiving from the NPDB a copy of the report, the hospital identifies an error in the practitioner's address. The hospital must submit a Correction Report with the corrected address. The Correction Report replaces the Initial Report.

Void Report

A Void Report, also referred to as a Void, is the withdrawal of a report in its entirety. When the reporting entity voids a report, the report is removed from the disclosable record of the subject of the report. A reporting entity may void a report at any time. The three reasons for voiding a report are:

• The report was submitted in error
• The action was not reportable because it did not meet NPDB reporting requirements
• The action was overturned on appeal

When the NPDB processes a Void, the NPDB provides the reporting entity with a Report Void Confirmation. The NPDB also sends a notification to the subject and to all queriers who received the previous version of the report within the past 3 years. All queriers who received the previous version of the report within the past 3 years are directed to destroy the prior report and any copies of it. The reporting entity and the subject of the report should review the information to ensure that the intended report was voided, and past queriers should note that the report was voided. For certain types of actions, the reporting entity also must provide a copy of the Report Void Confirmation to the appropriate state licensing board or state licensing or certification authority.

Example: A state medical board submits an Initial Report to the NPDB when it revokes a physician's license. Six months later, the revocation is overturned by a state court. The state medical board must void the Initial Report.

Revision-to-Action Report

A Revision-to-Action Report is a report of an action that modifies an adverse action previously reported to the NPDB. A Revision-to-Action Report does not replace a previously reported adverse action but rather is treated as a separate action that pertains to the previous action. Both reports become part of the disclosable record. The entity that reports an initial adverse action also must report any modification of that action.

Examples of when a Revision-to-Action Report should be submitted include:

• When additional sanctions have been taken against the subject of a report based on a previously reported incident
• When the length of action has been extended or reduced
• When clinical privileges, professional society membership, accreditation, program participation, or a license has been reinstated
• When the original suspension or probationary period has ended

Reporting entities do not need to submit a Revision-to-Action Report in cases in which the subject of the report will be reinstated automatically after the adverse action period is complete and the reporting entity selected "Yes" to the question on the related report regarding whether the subject of the report will be reinstated automatically without conditions.

The NPDB system will not accept a Revision-to-Action Report unless a related report was submitted previously. A Revision-to-Action Report is not available for submitting Medical Malpractice Payment Reports.

A Revision-to-Action Report is separate and distinct from a Correction Report. For example, if a hospital enters the date of action incorrectly on an Initial Report, a Correction Report must be submitted to make the necessary change to the date, and the Correction Report replaces the Initial Report. However, if the hospital reports an initial action to the NPDB to suspend a physician's clinical privileges for 60 days and subsequently reinstates the physician's privileges after reducing the suspension to 45 days, the hospital must submit a Revision-to-Action Report regarding the reinstatement. A Revision-to-Action Report is treated as an addendum to the Initial Report. Together, the Initial Report and the Revision-to-Action Report provide a more complete explanation of the events.

Example 1: A hospital reports a clinical privileges action when it suspends a practitioner's clinical privileges for 90 days for unprofessional conduct. The hospital later reduces the suspension to 45 days. Since this reduction in the length of the suspension modifies a previously reported action, the hospital must submit a Revision-to-Action Report. The Initial Report documents that the hospital suspended the subject's clinical privileges for 90 days, and the Revision-to-Action Report documents that the hospital reduced the suspension to 45 days. Note that in this example both reports — the 90-day suspension report and the 45-day suspension report — were correct when they were filed. Therefore, the change is noted with a Revision-to-Action Report, not a Correction Report.

Example 2: A state medical board reprimands a physician and mandates that she complete 5 hours of continuing education units (CEUs) within 3 months. The state board must submit an Initial Report, which documents that the state medical board reprimanded the physician and required her to complete the CEUs. The physician does not complete the CEUs within the allotted time, and the medical board places her license on probation until she completes the required CEUs. The medical board then must submit a Revision-to-Action Report, which documents that the state medical board placed the physician's license on probation until she completes the CEUs.

A Revision-to-Action Report is appropriate only if it modifies the previously submitted report.

Example 3: A state licensing board issues an order suspending a pharmacist's license for 3 months. In the order, the board states that the pharmacist must take additional training before the license is reinstated, and it states that the board must approve the pharmacist's choice of training. The board files an Initial Report with the NPDB reflecting the details of the order. The pharmacist returns to the board to seek approval of his choice of training, which the board grants in another formal order. The licensing board should not submit a Revision-to-Action Report after it approves the pharmacist's choice of training — even if the board publishes the second formal order — because nothing about the second order modified what was described in the Initial Report. (In addition, the published second order is not the type of adverse action that would require the board to file another Initial Report.)

When the NPDB processes a Revision-to-Action Report, the NPDB provides the reporting entity with a copy of the Revision-to-Action Report. The NPDB also sends a notification to the subject of the report. The reporting entity and the subject of the report should review the information to ensure that it is correct. For certain types of actions, reporters also must provide a copy of the Revision-to-Action Report to the appropriate state licensing board or state licensing or certification authority.

Notice of Appeal

A Notice of Appeal notifies the NPDB that a subject of a report has formally appealed a previously reported adverse action with the entity taking the action. A Notice of Appeal is attached to an existing report. It is separate and distinct from a subject's dispute of an NPDB report. Reporters must submit a Notice of Appeal for the following actions when the previously reported action is on appeal:

• State licensure and certification actions
• Federal licensure and certification actions
• Federal or state criminal convictions related to the delivery of a health care item or service
• Federal or state civil judgments related to the delivery of a health care item or service
• Exclusions from participation in federal or state health care programs
• Other adjudicated actions or decisions

When the NPDB processes a Notice of Appeal, the NPDB provides the reporting entity a copy of the original report with a copy of the Notice of Appeal appended. In addition, the NPDB sends a notification to the subject of the report and to all queriers who received the previous version of the report within the past 3 years.

Narrative Descriptions

For each report submitted to the NPDB, reporting entities are required to specify the action taken and include a detailed narrative describing the acts or omissions of the subject of the report upon which the action is based. MMPRs require a description of the alleged acts or omissions and injuries upon which the action or claim was based, and a separate description of the judgment or settlement and any conditions, including the terms of payment.

The narrative description must include sufficient detail to ensure that future queriers have a clear understanding of what the subject of the report is alleged to have done and the nature of and reasons for the event upon which the report is based. Narratives may not exceed 4,000 characters, including spaces and punctuation. Any characters over 4,000 will be truncated.

Narrative descriptions should be limited to statements of fact and should:

• Summarize the official findings or state the facts of the case
• Include a description of the circumstances that led to the action taken

Narrative descriptions must not include:

• URLs or references to external websites
• The proper names of or identifying information about any individuals (except the subject of the report), including patients, staff members, and the like

Narrative descriptions may include the name of the subject of the report, and individuals may be characterized in terms of their relationship (e.g., the patient, the chief of staff). Entities may wish to consult with their legal counsel regarding the wording of the narrative before submitting reports to the NPDB.

The NPDB reserves the right at any time after submission of a report to determine that a narrative description does not provide sufficient detail to ensure that future queriers have a clear understanding of what the subject of the report is alleged to have done. If the NPDB makes such a determination, the reporter is required to submit a Correction Report. Failure to submit a Correction Report in these circumstances may be treated by the NPDB as a failure by the reporting entity to have filed a required report.

Methods for Submitting a Report

Eligible entities may submit reports electronically through the Integrated Querying and Reporting Service (IQRS) on the NPDB website. Entities that prefer to generate reports using custom software may choose to submit reports through an external application. Entities that report via the Querying and Reporting XML Service (QRXS) must submit data using the format specified by the NPDB.

Basis for Action Codes

All submitted reports should contain Basis for Action Codes that accurately represent the reportable action. When submitting a report, choose the most accurate codes. Multiple codes may be selected if there are multiple reasons for the action(s) taken. A Basis for Action Code of "Other" should be used only if there are no codes that match the actual basis for action. Use appropriate codes from the codes list when submitting reports to assure complete and accurate reporting.

Report Processing

Each version of a report submitted to the NPDB system is assigned a unique Data Bank Control Number (DCN). This number is used to locate the report within the NPDB system.

When the NPDB processes a report, the NPDB provides the reporting entity with an electronic copy of the report. The DCN is prominently displayed on the copy. The DCN assigned to the most current version of the report always must be referenced in any subsequent action involving the report.

The reporting entity should review the report information to ensure that it is accurate. If the reporting entity identifies incorrect information in the report, a Correction Report must be submitted. If the entity inadvertently reported information for the wrong subject, the reporting entity must void the inaccurate report and submit a new report naming the correct subject. See also Types of Reports.

The NPDB also sends a notification to the subject of the report. The subject of the report should review the report information to ensure that it is accurate. (See Reviewing a Report in Chapter F: Subject Statements and the Dispute Process.)

Submitting a Copy of the Report to the Appropriate State Licensing Board or State Licensing or Certification Authority

Eligible entities that report certain actions to the NPDB also are required to provide to the appropriate state licensing board or state licensing or certification authority a copy of the NPDB Initial Report, Correction Report, Revision-To-Action Report, or Void Report. These actions include:

• Medical malpractice payments - entities must report information to the appropriate state licensing board(s) in the state in which the act or omission upon which the medical malpractice claim was based occurred or did not occur
• Clinical privileges actions - reporters must provide a copy to the appropriate state licensing board in the state in which the health care entity is located
• Professional society membership actions against physicians or dentists - reporters must provide a copy to the appropriate state licensing board in the state in which the health care entity is located
• Negative actions or findings by a peer review organization - reporters must provide a copy to the appropriate state licensing or certification authority
• Negative actions or findings by a private accreditation organization - reporters must provide a copy to the appropriate state licensing or certification authority

Report Forwarding by the NPDB

As an alternative to the reporting entity directly providing a copy of the NPDB report to state licensing and certification authorities (state boards), certain NPDB reporters may elect to send an electronic version of the report to the appropriate state boards through the NPDB's Electronic Report Forwarding service, provided that the state board has agreed to accept electronic notices of an action. Both the state board and the reporting entity must agree to use the Electronic Report Forwarding service in advance of forwarding an NPDB report. In addition, the reporting entity is responsible for selecting the appropriate state board. If a state board declines to participate in the Electronic Report Forwarding service, or if a reporting organization prefers not to use this feature for submitting a report, reporting entities remain responsible for mailing a copy of the report to the appropriate state board. In addition, if the state board does not view the electronically forwarded report, the reporting entity is notified and the reporting entity must mail a copy of the report to the appropriate state board.

IQRS Draft Capability

The IQRS includes a draft report feature for entering report data into input screens, then saving the document in draft status. The draft version of a report can be modified later. Draft reports may be saved for 30 days before they are automatically deleted. Reports saved as drafts are not considered official report submissions. Draft reports must be completed, submitted, and successfully processed by the NPDB to fulfill reporting requirements.

Subject Database

Creating and maintaining a Subject Database (which may include practitioner and organization subjects) can make entering the required information on the subject of a report or query quicker by automatically pre-populating forms with identifying information. This eliminates the need to retype data on these individuals and organizations.

When reporting or querying using a Subject Database, the IQRS retrieves all pertinent information from the entity's Subject Database to complete the appropriate screens. However, if a record in the Subject Database is incomplete (i.e., information is missing in required fields), the IQRS does not allow that subject data to populate the appropriate screens until the missing information is added.

Retrieving Historical Report and Query Summaries

There may be times when an eligible entity needs to search for specific organizations or individuals on whom it previously reported or queried (e.g., for a compliance audit). To address this need, the NPDB makes available to entities Historical Report Summaries and Historical Query Summaries. A Historical Report Summary is a listing by date of the reports submitted by the entity, and a Historical Query Summary lists by date the queries submitted by the entity. Both Historical Report Summaries and Historical Query Summaries are available back to June 2000. See Retrieving Historical Query Summaries.