By EWA MATUSZEWSKI
When a practicing physician dies, there is not only intense grief, but an entire gamut of professional details that require immediate attention. I recently faced this personal challenge and was admittedly adrift in confronting first and subsequent steps. Perhaps I should have known them already—but some of the medical associations and health plans I reached out to didn’t either. The question? Where is the checklist to guide me through the “un-credentialing” of a physician?

With the risk of identity theft high, it is imperative that no enterprising thief access physician credentials for nefarious purposes. Here is what I learned by creating my own checklist for steps that must be taken when a physician dies. (Note that information to “disenroll” applies to a retiring physician as well.) The following provide time-sensitive basics:

  • Meet with the practice manager to create an action plan for the first 15 days.
  • Assemble current employees to communicate pending changes in the practice and how their support is needed for a smooth transition.
  • Send an announcement via the patient portal to active patients. Draft and send a letter via US mail to the patients as well. This is not necessary for a fully retired physician unless the successor practice leaders want to issue a letter out of respect.
  • Procure about 15 certified copies of the death certificate, as they are needed for proof of death in a variety of scenarios.
  • Notify the State of Michigan’s Licensing and Regulatory Affairs (LARA) physician licensing board.
  • Notify the State of Michigan’s Licensing and Regulatory Affairs (LARA) pharmacy licensing board and the pharmacy-controlled substance registration office.
  • Contact the United States Drug Enforcement Administration (DEA). The original certificate with a letter indicating the physician is deceased should be sent to the regional office.
  • Notify the medical staff office at the hospitals where the physician had privileges.
  • Contact all health insurers of the termination date and to determine if the insurer has specific protocols that need to be followed.
  • Disable the deceased physician’s NPI number. This can be done by the person who is listed as the Authorized Official on the application. SSA (Social Security Administration) also informs the National Plan and Provider Enumeration System (NPPES) when their records indicate that a provider has died. This is a backup for NPI deactivation, but it does not happen overnight.
  • Contact the medical malpractice insurance carrier to cancel coverage. A copy of the death certificate is required to terminate coverage. Determine if “tail” coverage will be provided. If not, consider purchasing to protect against future claims.
  • Identify any open medical charts, either paper or EHR. Have a physician review the documentation. Follow Medicare audit guidelines for provider signatures. A deceased physician would quality for a Unique Signature Situation. The following verbiage should be entered in the patient’s chart: “The rendering physician was present at the (specify in-person, virtual or telephonic) encounter but was unable to sign the record due to death that occurred on XXX.” I checked with legal counsel to ensure this was appropriate.
  • Log into CAQH to update the physician’s information. Submit an email to [email protected] and make sure to include any of the following: death certificate, obituary, and letter stating that the provider is deceased. Provide the following information in the body of the email: provider’s name and CAQH ID number, name of person submitting the information contact information, and relationship with the provider.
  • Review any contracts that were signed by the deceased physician.
  • When in doubt, always contact an attorney.

Along with wills, trusts, Advance Directives, and medical powers of attorney that families should have on hand, this inventory should be added to the portfolio of administrative items to cover in the event of a physician’s death. While it’s a tool that no one ever wants to use, it can help guide practices and families during a time when many are preoccupied with grief and managing other estate details.

There are likely additional points to include beyond what I assembled from scratch. I would like to hear about them so I can help others prepare and avoid what I had to go through. In fact, if there is one New Year’s resolution to make and keep in 2024, we should ensure that administrative particulars are in place to handle the unexpected.