Institutional Privileging for Vascular Access: Building a Defensible Framework
Framework for building an institutional vascular access privileging program: scope of practice delineation, privilege categories, competency documentation, re-privileging, medical staff credentialing vs. nursing competency, and TJC compliance.
Institutional Privileging for Vascular Access: Building a Defensible Framework
Institutional privileging defines which clinicians are authorized to perform which vascular access procedures within a given institution. A robust privileging framework protects patients (by ensuring only qualified clinicians perform procedures), protects the institution (by creating a documented, defensible competency record), and enables quality oversight (by linking privileges to ongoing outcome data).
This guide provides a framework for building or auditing an institutional vascular access privileging program.
Parent guide: Vascular Access Credentialing: Complete Reference
Credentialing vs. Privileging vs. Competency: Key Distinctions
These three terms are related but distinct:
Credentialing: Verification of a clinician’s professional qualifications — licensure, education, certifications, training program completion. Credentialing asks: “Does this person have the background qualifications to request privileges?”
Privileging: The institution’s authorization for a specific clinician to perform specific procedures or provide specific patient care services. Privileging asks: “Is this person authorized to perform procedure X at this institution?” Privileges are institution-specific.
Competency: Ongoing demonstration that a clinician can perform a procedure or skill to defined standards. Competency asks: “Can this person perform this procedure safely right now?”
Relationship: Credentialing (qualifications) + demonstrated competency → institutional privileges. Privileges are then maintained through annual competency validation.
Regulatory Framework
The Joint Commission (TJC): Accredited hospitals must have a medical staff credentialing and privileging process (MS chapter) and a nursing competency program (HR chapter). TJC does not prescribe a specific format for vascular access privileging but expects institutions to have documented processes for advanced clinical procedures.
CMS Conditions of Participation: Hospitals must ensure clinical staff competency; procedures that require specialized training must have documented evidence of that training.
State nursing practice acts: Define the scope of practice for RNs, LPNs, APRNs, and other clinicians. Vascular access privileges must be consistent with state scope of practice law — institutions cannot grant privileges beyond the legal scope of a clinician’s license.
Privilege Categories for Vascular Access
A complete vascular access privileging framework should define privileges for each procedure tier:
Tier 1: Peripheral IV Insertion (PIV)
Standard bedside skill: Not typically formally privileged; included in nursing orientation and annual skills validation.
US-guided PIV: May require a supplemental credentialing record given the specialized skill involved. See Ultrasound Credentialing Requirements.
Tier 2: Midline Catheter Insertion
Eligible roles: Credentialed RN (typically, same training baseline as PICC), APRN, MD/DO.
Minimum requirements:
- Completion of PICC/midline insertion didactic training (same curriculum)
- Minimum proctored midline insertions (5–10)
- Competency checklist sign-off
Tier 3: PICC Insertion (Bedside)
Eligible roles: RN with specific training (VAT nurse); APRN; IR-trained PA/NP.
Minimum requirements:
- Completed PICC insertion training program (didactic + simulation + proctored cases)
- Minimum 10–15 proctored insertions
- Competency checklist signed by approved proctor
- Annual maintenance: 12 PICCs/year minimum
Documentation in privileging record:
- Training program completion certificate or letter from program director
- Proctored case log with proctor signatures
- Competency checklist copies
- Specialty certification (VA-BC) if held — not required for privileges but should be documented as evidence of expertise
Tier 4: Non-Tunneled CVC (IJ, Subclavian, Femoral)
Eligible roles: MD, DO, PA, NP (with hospital-granted privileges); not typically within RN scope of practice for IJ/subclavian/femoral access.
Requirements: Medical staff privileging process via medical staff office; training documentation per specialty training requirements.
Tier 5: Port Access
Eligible roles: Trained RN (VAT or designated IV therapy nurses); APRN.
Minimum requirements:
- Specific port access training (anatomy of port system, Huber needle technique, ANTT for port access)
- Minimum 5–10 proctored port accesses
- Annual competency: minimum access frequency (typically 6–12 port accesses per year)
Building the Privileging Documentation File
For each clinician with vascular access privileges, maintain a file containing:
At initial credentialing:
- Training program completion documentation
- Proctored case log with proctor attestation
- Knowledge assessment score and pass date
- Simulation competency sign-off
- Current nursing license copy
- Specialty certification (VA-BC, CRNI) if applicable
- CV/resume for clinical experience
Annual: 8. Annual case volume log (procedure counts per year) 9. Annual competency assessment documentation 10. Current license renewal copy 11. Certification renewal documentation
Privilege delineation form: A signed form specifying exactly which procedures the clinician is authorized to perform (e.g., “PICC insertion, bedside, US-guided; midline insertion; port access”). This form should be signed by both the clinician and a designated approver (department director, medical director).
Privilege Renewal and Suspension
Annual Renewal
Privileges should be formally renewed annually with verification that:
- License remains active and in good standing
- Case volume meets minimum threshold
- Annual competency assessment completed with passing result
- No patient safety events or quality concerns pending review
Suspension or Restriction
Privileges should be suspended or restricted when:
- Patient safety event or complication pattern is identified
- Volume falls below minimum and retraining has not been completed
- License is under investigation or suspended
- Clinician voluntarily requests supervised practice
Suspension process:
- Identify issue (outcome review, incident report, direct observation)
- Notify clinician of privilege suspension
- Conduct root cause analysis or performance review
- Determine remediation plan (retraining, proctoring, supervision)
- Document remediation completion and restore privileges or determine permanent restriction
Medical Staff Credentialing vs. Nursing Competency
Important distinction: Physicians, PAs, and NPs with hospital medical staff privileges go through the medical staff credentialing office for privileging. This process is separate from nursing competency programs.
For MD/PA/NP:
- CVC, surgical cutdown, IR procedures → medical staff privileging process
- PICC insertion (if MDs insert PICCs at the institution) → medical staff privilege for PICC, with documentation of training
For RNs:
- VAT PICC, midline, port access → nursing competency program with HR documentation
- RNs do not go through medical staff credentialing; they are validated through the nursing competency program
The institutional vascular access privileging program should address BOTH tracks and ensure consistent standards across clinical roles.
Linking Privileges to Quality Outcomes
A mature privileging program connects individual clinician privileges to outcome data:
Individual-level quality metrics:
- First-attempt success rate by inserter
- Catheter malposition rate by inserter
- CLABSI rate attributable to lines placed by individual inserter (challenging but informative)
- Bundle documentation compliance rate
How to use outcome data:
- Present aggregate data to all credentialed inserters for transparency and benchmarking
- Identify outliers (significantly below benchmark) for focused review and re-proctoring
- Recognize high performers as mentors or proctors
- Trend individual performance over time as volume increases
Related Resources
Related guides:
Related policies:
References
- Gorski LA, et al. (2021). INS Infusion Therapy Standards of Practice (Standard 13). J Infus Nurs, 44(Suppl 1).
- The Joint Commission. (2024). Hospital Accreditation Standards: MS Chapter (Medical Staff); HR Chapter (Human Resources). Oakbrook Terrace, IL: TJC.
- AVAR. (2023). Vascular Access Position Statements on scope of practice and credentialing. Retrieved from avar.org.