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“30 days” appears four times in a hospital’s NPDB obligations, and it means something different every time. One is a duration threshold on the action. One is a filing deadline. One is a deadline to request a hearing. One is the delay before a sanction takes effect. Medical staff offices that collapse them into a single “30-day rule” get the reportability question wrong in both directions, and the provision that actually catches hospitals — surrender of clinical privileges while under investigation — has no 30-day threshold on it at all.
This page states what triggers a mandatory hospital report, when it must be filed, who else reports what, and what the query obligation requires, cited to 45 CFR part 60 and the NPDB Guidebook, verified against both on 26 August 2026. Where the Guidebook elaborates on the regulation it is identified as the Guidebook; where the two differ in emphasis, the regulation governs.
Scope. This is a description of a published federal requirement and its sources. It is not legal advice, and it does not tell you whether a particular event at your organisation is reportable. That determination belongs to your medical staff bylaws, your counsel, and — for genuinely ambiguous facts — the NPDB itself.
The four 30-days, and which is which
| What it measures | The rule | Citation |
|---|---|---|
| Duration threshold on the action | A professional review action is reportable only if it adversely affects clinical privileges for a period longer than 30 days | 45 CFR 60.12(a)(1)(i) |
| Filing deadline | The report must be submitted to the NPDB within 30 days following the action to be reported | 45 CFR 60.5 |
| Hearing request | A hospital served with a notice of noncompliance may request a hearing within 30 days after receipt of that notice | 45 CFR 60.12(c)(1) |
| Sanction commencement | Loss of HCQIA immunity runs for 3 years beginning 30 days after the entity’s name is published in the Federal Register | 45 CFR 60.12(c)(1) |
The first two are the pair that gets blurred. The threshold governs whether there is anything to report. The deadline governs when. A 21-day suspension is not reportable and no clock ever starts; a 45-day suspension is reportable and the filing window applies to it. Neither number tells you anything about the other.
And the surrender trigger below sits outside this table entirely. It carries no duration threshold, which is precisely why it is missed.
What triggers a mandatory hospital report
Section 60.12(a)(1) requires each health care entity to report to the NPDB — and to provide a copy of the report to the Board of Medical Examiners in the state in which the entity is located — the following:
- Any professional review action that adversely affects the clinical privileges of a physician or dentist for a period longer than 30 days. (60.12(a)(1)(i))
- Acceptance of the surrender of clinical privileges, or of any restriction of such privileges, by a physician or dentist while that practitioner is under investigation by the entity relating to possible incompetence or improper professional conduct, or in return for not conducting such an investigation or proceeding. (60.12(a)(1)(ii))
- A professional review action taken by a professional society concerning a physician or dentist. (60.12(a)(1)(iii))
Two definitions do most of the work. Adversely affecting means “reducing, restricting, suspending, revoking, or denying clinical privileges or membership in a health care entity” (60.3). A professional review action must be taken in the course of professional review activity, based on the practitioner’s professional competence or professional conduct, and must adversely affect or potentially adversely affect clinical privileges or professional society membership (60.3).
The same definition carves out what is not a professional review action. Actions taken primarily on the basis of a practitioner’s association or non-association with a professional society, their fees, their advertising or other competitive acts intended to solicit or retain business, their participation in prepaid group health plans or salaried employment, their supervision of or association with a particular class of practitioner, or “any other matter that does not relate to the competence or professional conduct of a health care practitioner” are excluded (60.3). A restriction imposed for a billing dispute or an exclusivity contract is not a reportable adverse action, however it is written up.
The reporting duty covers physicians and dentists. The query duty covers everyone.
This asymmetry is the single most common structural error in hospital NPDB policy. Section 60.12(a)(1) is mandatory only as to physicians and dentists. Section 60.12(a)(2) says a health care entity may report the same categories of action concerning other health care practitioners — permissive, not required.
Section 60.17(a), by contrast, requires a hospital to query “concerning a health care practitioner,” without narrowing to physicians and dentists. A hospital that maps its query list to its mandatory-report list will under-query advanced practice providers, podiatrists, psychologists and allied practitioners it is obliged to check.
The duration threshold is measured on day 31
The statutory phrase is “for a period longer than 30 days.” The Guidebook is explicit that the test turns on effect, not drafting: the NPDB “has consistently interpreted ‘adversely affects’ to mean the impact of the restriction, not the manner in which the restriction is written.” It follows that a restriction “is reportable to the NPDB once that restriction has been in place for 31 days.”
Several consequences follow that hospitals routinely get wrong:
- An expected end date is irrelevant. Reportability turns on how long the restriction is in fact in effect. A restriction intended to last two weeks that runs to six is reportable.
- Indefinite restrictions count. A significant proportion of reported privileges actions are “indefinite” in length — structured around the practitioner demonstrating competence rather than around a date. If such an action is in effect for more than 30 days, it must be reported (Guidebook).
- Proctoring can be a restriction. If, as a result of a professional review action related to competence or conduct, a practitioner cannot perform procedures without a proctor’s approval or presence, that is a restriction on privileges; if it lasts longer than 30 days it must be reported. The number of cases to be proctored at the outset is irrelevant. Proctoring that merely observes, without the proctor needing to be present or to approve care, is treated differently (Guidebook).
- The label on the action does not matter. “An action must be reported to the NPDB based on whether it satisfies NPDB reporting requirements and not based on the name affixed to the action.” Immediate, summary, emergency or precautionary — if it remains in effect for more than 30 days, it must be reported (Guidebook).
Summary suspensions are the one exception to “wait and see”
Privileges actions are generally reportable once made final by the entity. Summary suspensions are not: per the Guidebook, they are reportable if in effect or imposed for more than 30 days even if they are not final, because the practitioner’s procedural rights follow the suspension rather than preceding it.
Three operational rules attach to that:
- A summary suspension of indefinite length that has not yet lasted more than 30 days, but is expected to, may be reported. If it ultimately does not last more than 30 days, the report must be voided.
- Where a review body confirms the suspension, the action is treated as having taken effect when it was first imposed by the hospital official, not when the committee confirmed it.
- If the authorised committee does not confirm the action, or takes a different action, a Revision-to-Action Report is required; if it vacates the suspension, the entity must void the report.
The distinct machinery of clinical peer review — a hearing that comes after the protective act rather than before it — is what makes this exception coherent rather than arbitrary.
The filing clock: 30 days following the action
Section 60.5 sets one deadline for everything a health care entity reports under section 60.12: the information “must be submitted to the NPDB within 30 days following the action to be reported.” The same section requires reporters of adverse actions to provide their state authority with a copy of the report they submit.
Note what that phrase does and does not say. The window runs from the action to be reported. For a suspension that becomes reportable only by crossing the duration threshold, the reportable event and the day the restriction began are not the same day — the regulation does not start a filing clock on an action that was not yet reportable. Where the sequencing is genuinely unclear on your facts, that is a question for the NPDB, not for a template policy.
Section 60.6 carries the maintenance duties that follow. Errors or omissions discovered after filing must be corrected “as soon as possible,” and to the Board of Medical Examiners as well. Any revision of the reported action — reversal of a professional review action being the named example — must itself be reported, subject to the same time constraints. The NPDB will not readjudicate the case or examine the underlying merits.
Surrender under investigation: the trigger with no threshold
This is the provision that catches hospitals, and it catches them for a structural reason: it is the only mandatory trigger with no duration test, no requirement that a professional review action ever be taken, and no requirement that the practitioner know anything.
Under 60.12(a)(1)(ii), the entity must report its acceptance of a physician’s or dentist’s surrender or restriction of clinical privileges (A) while under investigation relating to possible incompetence or improper professional conduct, or (B) in return for not conducting such an investigation or proceeding. The Guidebook states the point flatly: “Investigations should not be reported to the NPDB. However, a surrender of clinical privileges or failure to renew clinical privileges while under investigation or to avoid investigation must be reported.”
“Investigation” is broader than your bylaws say it is
The NPDB interprets the word expansively, and — decisively — not by reference to the hospital’s own definition. From the Guidebook:
- The term “is not controlled by how that term may be defined in a health care entity’s bylaws or policies and procedures.” The NPDB may look at those documents for assistance but “retains the ultimate authority to determine whether an investigation exists.”
- An investigation “runs from the start of an inquiry until a final decision on a clinical privileges action is reached.” It “begins as soon as the health care entity begins an inquiry and does not end until the health care entity’s decision-making authority takes a final action or makes a decision to not further pursue the matter.”
- It “is not limited to a health care entity’s gathering of facts.”
- It must be focused on the practitioner in question and must concern that practitioner’s professional competence or conduct, and generally should be the precursor to a professional review action.
- A routine or general review of cases is not an investigation. A routine review of a particular practitioner is not an investigation.
The line that matters operationally is the last pair set against one more: “A routine, formal peer review process under which a health care entity evaluates, against clearly defined measures, the privilege-specific competence of all practitioners is not considered an investigation… However, if a formal, targeted process is used when issues related to a specific practitioner’s professional competence or conduct are identified, this is considered an investigation for the purposes of reporting to the NPDB.”
In the vocabulary most US hospitals actually use, that is the boundary between ongoing and focused review. A hospital’s routine periodic evaluation of every practitioner is not an investigation; a targeted evaluation opened because a concern was identified about one practitioner can be. Any organisation whose reporting policy leans on that distinction should be able to state precisely where its own OPPE and FPPE processes sit relative to it — including which committee action opens a targeted review, and which one closes it.
The practitioner’s awareness is irrelevant
Repeated three times in the Guidebook, in three different contexts: “A practitioner’s awareness that an investigation is being conducted is not a requirement for filing a report with the NPDB.” There is no requirement that the practitioner be notified of the investigation at all.
Resignation, withdrawal and non-renewal are all in scope
Per the Guidebook, three departures that hospitals often treat as clean exits are not:
- Withdrawal of a renewal application. Voluntary withdrawal of an initial application for appointment or privileges, before a final professional review action, generally should not be reported. But withdrawal of an application for renewal, while under investigation or in return for not conducting one, must be reported.
- Simply not reapplying. Non-renewals generally should not be reported. But where a practitioner does not apply for renewal while under investigation, or in return for not conducting an investigation or taking a professional review action, “the event is considered a surrender while under investigation and must be reported.”
- Surrender during a summary suspension. If a practitioner surrenders privileges during a summary suspension — whether or not a review body has confirmed the suspension — that action must be reported, because the surrender is occurring either while under investigation or in return for not conducting one.
A separate line worth marking: a decision not to renew privileges that is based on the practitioner’s professional competence or conduct is itself an action against privileges under the Guidebook — a different route to the same report.
What the file has to show
A hospital reporting a surrender-while-under-investigation “should have evidence of an ongoing investigation at the time of surrender, or evidence of a plea bargain,” and “should be able to produce evidence that an investigation was initiated prior to the surrender.” The Guidebook names acceptable examples: committee minutes or excerpts, orders from hospital officials directing an investigation, or notices to practitioners of an investigation — “although there is no requirement that the health care practitioner be notified or be aware of the investigation.”
That is a records requirement, not a reporting requirement, and it runs the opposite way from the awareness rule: you do not have to tell the practitioner, but you do have to be able to show a third party when the inquiry opened. Committees that document a targeted review only after it concludes cannot produce that evidence.
One narrow exclusion
For NPDB purposes no distinction is drawn between temporary privileges — including emergency and disaster privileges — and ordinary privileges. The exception, per the Guidebook: where temporary privileges are granted for a specific period with no opportunity for renewal, both parties agree they are temporary, and they expire while the practitioner is under investigation, a report should not be submitted, because an expiry with no renewal available cannot be a non-renewal or a surrender.
Who reports what: four regimes that do not share a rule
Part 60 is not one reporting requirement. It is several, applying to different reporters, covering different subjects, on different triggers. A page — or a policy — that merges them is wrong for every reader.
| Reporter | What must be reported | Subjects covered | Citation |
|---|---|---|---|
| Hospitals and other health care entities | Adverse clinical privileges actions longer than 30 days; surrender or restriction while under investigation or to avoid one | Mandatory: physicians and dentists. Permissive: other practitioners | 60.12 |
| Entities making malpractice payments, including insurers and self-insured entities | Any payment under an insurance policy, self-insurance or otherwise, for the benefit of a practitioner, in settlement or satisfaction of a claim or judgment. Waiver of an outstanding debt is not a “payment” | All health care practitioners | 60.7 |
| Boards of Medical Examiners | Licence revocation, suspension or other restriction; censure, reprimand or probation; licence surrender — where based on professional competence or conduct | Physicians and dentists | 60.8 |
| States (licensing and certification authorities) | Adverse actions resulting from formal proceedings, dismissals or closures by reason of surrender, other losses of licence or certification, and negative actions or findings | Practitioners, entities, providers and suppliers | 60.9 |
| Peer review organisations and private accreditation entities | Negative actions or findings resulting from formal proceedings | Practitioners, entities, providers and suppliers | 60.11 |
| Federal agencies, state law and fraud enforcement agencies, and health plans | Other adjudicated actions or decisions, plus criminal convictions, civil judgments and programme exclusions in their respective sections | Practitioners, providers and suppliers | 60.13-60.16 |
Four distinctions matter more than the rest:
- The malpractice payer reports, not the practitioner and not the hospital as employer. Section 60.7(a) attaches the duty to the entity making the payment “for the benefit of a health care practitioner.” A self-insured hospital that pays on a practitioner’s behalf is a reporting payer under 60.7, and that duty is entirely separate from anything it owes under 60.12. The report also goes to the state licensing board in the state where the act or omission occurred.
- Two different “surrenders” live in Part 60. Surrender of clinical privileges (60.12) is a hospital’s report. Voluntary surrender of licence or certification is separately defined at 60.3 — a surrender made after notification of investigation or a formal official request by a licensing authority, or in exchange for that authority ceasing or not conducting an investigation — and is reported by the licensing side, not by you.
- Health plans face a money penalty; hospitals do not. A health plan that fails to report an other adjudicated action is subject to a civil money penalty of not more than $25,000 for each action not reported (60.16(e)). No equivalent per-report penalty applies to a hospital’s failure under 60.12 — the hospital’s exposure is different in kind, and worse in effect. See below.
- Health plan paneling decisions are explicitly outside the definition. The definition of “other adjudicated actions or decisions” at 60.3 specifically excludes clinical privileging actions taken by federal agencies or state law and fraud enforcement agencies, and “similar paneling decisions made by health plans.” A network termination unrelated to fraud, abuse or quality of care is likewise excluded.
The query obligation: at appointment, then every two years
Section 60.17(a) requires each hospital, directly or through an authorised agent, to request information from the NPDB:
- At the time a practitioner applies for a position on the medical staff — courtesy or otherwise — or for clinical privileges at the hospital; and
- Every 2 years for any practitioner who is on the medical staff, courtesy or otherwise, or who holds clinical privileges at the hospital.
There is no fine for failing to query. What section 60.17(b) supplies instead is a presumption: “Any hospital which does not request the information as required in paragraph (a) of this section is presumed to have knowledge of any information reported to the NPDB concerning this health care practitioner.”
The mirror of that presumption is the protection in 60.17(c): a hospital may rely on the information the NPDB provides, and “shall not be held liable for this reliance unless the hospital has knowledge that the information provided was false.”
The disclosure consequence most hospitals have never read
Section 60.18(a)(1)(v) makes NPDB information — including reports filed under 60.7, 60.8 and 60.12 — available to an attorney, or an individual representing themselves, who has filed a medical malpractice action or claim against a hospital, concerning a specific practitioner also named in that action. It is available on one condition: “only upon the submission of evidence that the hospital failed to request information from the NPDB, as required by 60.17(a),” and may be used solely with respect to that litigation.
That is the operative sanction for a missed query. A gap in the two-year cycle is not merely an audit finding; it is the key that unlocks the practitioner’s NPDB file to the plaintiff in a suit against the hospital.
Continuous Query versus One-Time Query
The NPDB offers two query products, and the difference is not administrative convenience.
| One-Time Query | Continuous Query | |
|---|---|---|
| What it is | Submit a name, receive a response containing all NPDB reports on that subject as of that moment (formerly “Traditional Query”) | Enrol a practitioner for a 12-month period |
| What you receive | A point-in-time response | Confirmation of enrolment, all current reports (equivalent to a One-Time Query response), and notice of new reports |
| New reports during the period | Not notified — you learn of them at your next query | Notified within 24 hours of the NPDB’s receipt of the report, throughout the enrolment period |
| Satisfies the 60.17 mandate | Yes, when performed at appointment and every 2 years | Yes — hospitals that enrol their practitioners in Continuous Query fulfil the mandatory querying requirements |
The consequential difference is latency. With one-time querying, a report filed one month after a reappointment cycle sits undiscovered for up to two years. With Continuous Query, the same report surfaces within 24 hours. Both are compliant; only one closes the window.
Two operational points follow. First, enrolment runs for 12 months while the statutory cycle runs to two years, so a hospital relying on Continuous Query to satisfy 60.17 must keep enrolment current — a lapse is a gap in the same obligation. Second, both query types can be submitted through the NPDB’s Integrated Querying and Reporting Service or through an external application, so the choice is not constrained by how your credentialing software connects.
Self-Query is a separate service, available to practitioners and organisations that want to see reports on themselves; it is not a substitute for the hospital’s obligation.
What failure to report actually costs
Section 60.12(c)(1) sets out a sequence, not a fine:
- If the Secretary has reason to believe a health care entity has substantially failed to report, the Secretary will conduct an investigation.
- If the entity is found not to have complied, the Secretary issues written notice describing the noncompliance, offering an opportunity to correct it, and stating the entity may request a hearing within 30 days after receipt of the notice. The request must identify material factual issues in dispute that are both substantive and relevant; a hearing is denied if the request is untimely, states no such issues, or states issues that are frivolous or inconsequential.
- If a hearing is denied, or if the entity is found noncompliant at hearing, the Secretary will publish the entity’s name in the Federal Register.
- In that case the immunity protections of section 411(a) of HCQIA “will not apply to the health care entity for professional review activities that occur during the 3-year period beginning 30 days after the date of publication of the entity’s name in the Federal Register.”
Read what that removes. HCQIA’s grant of immunity is the reason a hospital can conduct peer review at all without every adverse finding becoming a damages claim by the practitioner. Losing it for three years does not fine the hospital; it disarms its peer review process prospectively, for every practitioner, while leaving the obligation to conduct that peer review fully in place. A hospital in that position is exposed on the actions it takes, and exposed under separate confidentiality regimes if it declines to act.
Boards of Medical Examiners carry a parallel duty: each Board must report any known instance of a health care entity’s failure to report under 60.12(a)(1), and must simultaneously report it to the appropriate state licensing board (60.12(b)). Your state Board is a reporting channel for your own noncompliance.
Two further penalties bound the system. Improper disclosure of NPDB information carries a civil money penalty stated in the regulation as up to $11,000 per violation (60.20(b)) — HHS civil money penalty amounts are subject to annual inflation adjustment, so verify the current figure rather than relying on the number printed in Part 60. And section 60.22 immunises reporters: an entity is not liable in a civil action brought by the subject of a report unless it had actual knowledge of the falsity of the information reported. Accurate reporting is the protected act; the risk sits on not reporting.
What is not reportable
An over-reporting policy is its own failure, and the regulation is as specific about the negative as the positive:
- Investigations themselves. Only the surrender or non-renewal that occurs during or to avoid one (Guidebook).
- Actions of 30 days or fewer. Adverse privileges actions “should not be reported to the NPDB unless they adversely affect the practitioner’s clinical privileges for a period longer than 30 days” (Guidebook).
- Anything not based on competence or conduct — fees, advertising, competitive acts, association with a professional society, salaried employment or prepaid plan participation, and “any other matter that does not relate to the competence or professional conduct” of the practitioner (60.3).
- Voluntary withdrawal of an initial application before a final professional review action, generally (Guidebook).
- Ordinary non-renewal not connected to an investigation or to competence or conduct, generally (Guidebook).
- Expiry of non-renewable temporary privileges under investigation, on the narrow conditions above (Guidebook).
- Consent judgments entered to provide security for civil settlements where there was no finding or admission of liability, which the definition of “civil judgment” at 60.3 excludes.
When the practitioner disputes the report
The subject receives a copy of every report, including revisions and corrections, automatically and free of charge (60.6(c), 60.19(a)). On receipt the subject may accept the report, append a permanent statement to it, or dispute it (60.6(d)).
The dispute path at 60.21 puts the first move on the reporting entity. The report enters “disputed status” and is transmitted as such to queriers, the reporting entity and the subject. The subject must attempt to resolve the dispute with the reporting entity; if the entity does not revise the report or does not respond within 60 days, the subject may request Secretarial review, which the Secretary will decide within 30 days of the request absent good cause for extension.
The scope of that review is narrow and worth knowing before your committee prepares a response: the Secretary “will only review the accuracy of the reported information, and will not consider the merits or appropriateness of the action or the due process that the subject received.” Arguments about whether the action was fair are outside the process. Arguments about whether the report accurately describes what happened are inside it.
Building this into medical staff operations
Four points where policies most often fail, each traceable to a specific provision above:
- Define, in writing, the committee act that opens and closes a targeted review — and date it. The surrender trigger turns on whether an investigation was under way at the moment of surrender, and the Guidebook expects contemporaneous evidence of when it opened.
- Separate the query roster from the report roster. The query duty reaches every practitioner on the medical staff or holding privileges; mandatory reporting reaches physicians and dentists.
- Set a day-31 review on every open restriction. Indefinite and competence-conditioned restrictions become reportable by elapsing, with no further committee action to prompt anyone.
- Handle exit paperwork as a reportability question, not an HR question. Resignation, withdrawal of a renewal application and quiet non-renewal are all capable of being reportable surrenders.
NPDB obligations sit alongside, not inside, accreditation requirements. A surveyor assessing credentialing under an accreditor’s standards is asking a different question from the one Part 60 asks, though the same file answers both — see how CMS deeming authority is actually granted and the National Patient Safety Goals for that adjacent territory, and immediate jeopardy removal for the regulatory path a competence failure can take on the survey side. For the peer review committee’s own work product, M&M conference structure and the PSO work product privilege cover protections that operate independently of NPDB reporting — the privilege that shields deliberation does not suspend the duty to report the resulting action. Broader hospital quality and safety practice sits on the patient safety and infection prevention hub, and credentialing operations extend to vendor credentialing for facility access. Quality and safety professionals formalising this work often hold the CPHQ or CPPS credential.
Frequently asked questions
Does a hospital have to report a 30-day suspension?
No. Section 60.12(a)(1)(i) requires reporting only where privileges are adversely affected for a period longer than 30 days. A suspension of exactly 30 days does not meet the threshold. Per the Guidebook, a restriction becomes reportable once it has been in place for 31 days.
What is the NPDB reporting deadline?
Thirty days following the action to be reported (45 CFR 60.5). This is a separate number from the 30-day duration threshold in 60.12(a)(1)(i) and the two should never be conflated: one asks whether an action is reportable, the other asks by when.
Is a physician’s resignation while under investigation reportable?
If the hospital accepts the surrender of clinical privileges while the physician is under investigation relating to possible incompetence or improper professional conduct, or in return for not conducting such an investigation, yes — 60.12(a)(1)(ii). There is no minimum duration and no requirement that any professional review action have been taken. Whether a specific departure meets that description is a determination for your bylaws and counsel, not for this page.
Does the practitioner have to know an investigation is open?
No. The Guidebook states in three separate contexts that “a practitioner’s awareness that an investigation is being conducted is not a requirement for filing a report with the NPDB,” and that there is no requirement the practitioner be notified.
Is an OPPE or FPPE process an investigation for NPDB purposes?
A routine, formal peer review process evaluating all practitioners against clearly defined measures is not an investigation. A formal, targeted process opened because issues about a specific practitioner’s competence or conduct were identified is an investigation for NPDB reporting purposes. The Guidebook is explicit that the term is not controlled by how a hospital’s bylaws define it.
Do hospitals have to report nurse practitioners, PAs and other non-physician practitioners?
Not as a mandatory matter. Section 60.12(a)(1) is mandatory for physicians and dentists; 60.12(a)(2) makes reporting on other health care practitioners permissive. The query obligation under 60.17 is not limited that way.
How often must a hospital query the NPDB?
At the time a practitioner applies for a medical staff position (courtesy or otherwise) or for clinical privileges, and every 2 years thereafter for any practitioner on the medical staff or holding privileges (60.17(a)).
Does Continuous Query satisfy the mandatory query requirement?
Yes. Per the NPDB, hospitals that enrol their practitioners in Continuous Query fulfil the mandatory querying requirements. Enrolment runs for 12 months and delivers notice of new reports within 24 hours of the NPDB receiving them.
What happens if a hospital does not report?
The Secretary investigates, issues a notice of noncompliance with a 30-day window to request a hearing, and on a finding of substantial failure publishes the entity’s name in the Federal Register. HCQIA section 411(a) immunity then does not apply to that entity’s professional review activities for three years beginning 30 days after publication (60.12(c)(1)).
Is a proctoring requirement reportable?
It depends on the form and duration. Where a practitioner cannot perform procedures without a proctor’s approval or presence, following a professional review action related to competence or conduct, and that lasts longer than 30 days, the Guidebook treats it as a reportable restriction. Observational proctoring that does not gate care is treated differently.
Sources
- 45 CFR part 60 — National Practitioner Data Bank, the governing regulation (78 FR 20484, 5 April 2013, as amended), verified via the eCFR on 26 August 2026.
- NPDB Guidebook — Adverse Clinical Privileges Actions, HRSA, for the interpretation of “investigation,” summary suspensions, proctoring and the day-31 rule.
- NPDB Guidebook — Submitting a Query, HRSA, for One-Time Query, Continuous Query and Self-Query.
- Health Care Quality Improvement Act of 1986, title IV of Public Law 99-660, 42 U.S.C. 11101 et seq., the statute Part 60 implements.
Part 60 is the federal requirement. It does not displace separate state-law reporting duties, which vary — and the regulation itself routes a copy of your NPDB report to the state Board of Medical Examiners (60.12(a)(1)) and to your state authority (60.5). Where a specific event’s reportability is genuinely unclear, the NPDB accepts questions directly; that is the correct escalation, not a policy assumption.








