Guest guest Posted January 14, 2012 Report Share Posted January 14, 2012 Historically, hospital systems like to keep the gravy train going within their own system. From acute care to rehab to home health to outpatient services, the unwritten rule is to keep the patient within the hospital system, not for continuity of care as much as increased profits. Hospital systems are jumping on the ACO bandwagon and are buying out physician practices within surrounding communities. Generally speaking, hospital systems do have outpatient physical therapy satellites in communities. This means there isn't inconvenience to patients in various communities surrounding the large hospital headquarters. Reality... hospital systems have physicians who use hospital referral pads when making referrals. People who have this piece of paper in their hot little hands contact or choose from services on that sheet of paper. The choices on that sheet of paper only direct the hospital patients to hospital locations for services. It is completely unheard of for a hospital system to provide options outside of the system. It is also unheard of for that piece of paper to communicate freedom of choice for services. Hospital systems have monopolized this way for years without divulging facts & the freedom of choice to patients within their system. Hospital systems have a very large chunk of a population in any area who utilize services. Hospital systems monitor referral patterns. Private practices and freedom of choice have been ignored for years on this particular topic. I'm not for more and more regulations. I think it creates increased cost to verify medical staff privileges. Does this truly limit freedom of choice? Not completely. Remember, patients have the freedom to choose and that freedom isn't captured by any hospital system anyways because full disclosure doesn't occur in the real world. It forces hospital systems to grant every physician within their system medical staff privileges. Remember, the unwritten rule is to refer within the system. The only logical way to determine departmental impact of this - because really, you are all talking money and the loss of revenue - is to dig into your databases and analyze your top 25 referral sources. How many of those referral sources are not already within the hospital system? And... from that, how many of those currently within the hospital system do not have medical staff privileges? To understand the full " effect " of this, what's the data indicate? And, for those of you in private practice. Now would be a nice time to question your top referral sources and learn who has privileges where. You can educate them on their options for where to refer for physical therapy services based on this new regulation. If you happen to have referral sources without privileges and you just happen to compete with a hospital system - especially a hospital system that isn't a team player in the community, you could share a referral source NPI number and contact your Medicare payer questioning if they have paid for services at the hospital site. Selena Horner, PT ton, MI > > Good afternoon for those practicing in hospitals that see outpatients how is the new CMS interpretations affecting you if the doctor is not on staff of the hospital they can no longer refer to the hospital. I copied the language and the link below it was effective November 18, 2011. > > http://www.cms.gov/transmittals/downloads/R72SOM.pdf > > §482.56( Standard: Delivery of Services > Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital's medical staff to order the services in accordance with hospital policies and procedures and State laws. > Interpretive Guidelines §482.56( > Rehabilitation services must be ordered by a qualified and licensed practitioner who is responsible for the care of the patient. The practitioner must have medical staff privileges to write orders for these services. Privileges must be granted in a manner consistent with the State's scope of practice law, as well as with hospital policies and procedures governing rehabilitation services developed by the medical staff and approved by the governing body. Practitioners who may be granted privileges to order rehabilitation services include physicians, and may also, in accordance with hospital policy, be extended to Nurse Practitioners, Physicians' Assistants, and Clinical Nurse Specialists as long as they meet the parameters of this requirement. Although the following licensed professionals are also considered " practitioners " in accordance with Section 1842((18)© of the Social Security Act, they generally would not be considered responsible for the care of the patient or qualified to order rehabilitation services: Certified registered nurse anesthetist (Section 1861(bb)(2) of the Act); Certified nurse-midwife (Section 1861(gg)(2) of the Act); Clinical social worker (Section 1861(hh)(1) of the Act); Clinical psychologist (for purposes of Section 1861(ii) of the Act and as defined at 42 CFR 410.71); or registered dietician or nutrition professional. > > L. , PT, DPT, MBA > Director, Physical Rehabilitation Services > East Orange General Hospital > phone > fax > pager > " An ounce of prevention is worth a pound of cure. " > > > > ________________________________________________________________________________\ ________________ > IMPORTANT: This message contains confidential information and is intended only for the individual(s) named. > If you are not the named addressee, you are not authorized (either explicitly or implicitly) to disseminate, > distribute or copy this e-mail in any manner whatsoever. Please notify the sender immediately by e-mail if you > received this e-mail in error and delete this e-mail from your system. Unintended transmission shall not > constitute waiver of the attorney-client or any other applicable privilege. E-mail transmission cannot be > guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive > late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions > in the contents of this message, which arise as a result of e-mail transmission. > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 16, 2012 Report Share Posted January 16, 2012 I have owned a Private Practice and now I manage the Rehab Dept. of a large hospital. Our hospital system does not require our employed physicians to refer to the hospital's outpatient clinics. However, we do cultivate a culture around easing the way of our patient's through our multiple layers of care. We compete with private practices and physician owned practices just as you do. I am sure that not all hospitals operate like we do. That said, it seems that many who post on this list serve seem to be dividing our profession by labeling hospital outpatient systems as the enemy. That is painful given that many hospital Rehab Directors are quite active in the APTA, operate excellent practices that meet Joint Commission requirements ( which are very stringent and cost a lot resources to meet) and have to figure out ways to serve the uninsured. When I was in private practice, I had access to many contracts that the hospital systems in town could not get. In fact, the best contracts in town are not available to my hospital system but are available to private practitioners. This is just business. No one gets everything. Here in Oregon, our system is going to be part of an ACO. I envision that we will need some help in treating the extra 600,000 Oregonians that are going to become insured. Will the reimbursement be good? I don't think so. Will we need to come up with a new model to deliver care? I think so. Will that involve practices that are not a part of our system? I think so. However, we will choose carefully. Our average number of visits per patient is between 6 - 7. Our outcomes are great and our patients are satisfied. So, we will want to partner with practices that can match our outcomes and our average number of visits. I am hopeful that there will be many colleagues who will want to work with us. From: PTManager [mailto:PTManager ] On Behalf Of selenahorner Sent: Saturday, January 14, 2012 2:41 PM To: PTManager Subject: Re: outpatient referrals by nonstaff MDs Historically, hospital systems like to keep the gravy train going within their own system. From acute care to rehab to home health to outpatient services, the unwritten rule is to keep the patient within the hospital system, not for continuity of care as much as increased profits. Hospital systems are jumping on the ACO bandwagon and are buying out physician practices within surrounding communities. Generally speaking, hospital systems do have outpatient physical therapy satellites in communities. This means there isn't inconvenience to patients in various communities surrounding the large hospital headquarters. Reality... hospital systems have physicians who use hospital referral pads when making referrals. People who have this piece of paper in their hot little hands contact or choose from services on that sheet of paper. The choices on that sheet of paper only direct the hospital patients to hospital locations for services. It is completely unheard of for a hospital system to provide options outside of the system. It is also unheard of for that piece of paper to communicate freedom of choice for services. Hospital systems have monopolized this way for years without divulging facts & the freedom of choice to patients within their system. Hospital systems have a very large chunk of a population in any area who utilize services. Hospital systems monitor referral patterns. Private practices and freedom of choice have been ignored for years on this particular topic. I'm not for more and more regulations. I think it creates increased cost to verify medical staff privileges. Does this truly limit freedom of choice? Not completely. Remember, patients have the freedom to choose and that freedom isn't captured by any hospital system anyways because full disclosure doesn't occur in the real world. It forces hospital systems to grant every physician within their system medical staff privileges. Remember, the unwritten rule is to refer within the system. The only logical way to determine departmental impact of this - because really, you are all talking money and the loss of revenue - is to dig into your databases and analyze your top 25 referral sources. How many of those referral sources are not already within the hospital system? And... from that, how many of those currently within the hospital system do not have medical staff privileges? To understand the full " effect " of this, what's the data indicate? And, for those of you in private practice. Now would be a nice time to question your top referral sources and learn who has privileges where. You can educate them on their options for where to refer for physical therapy services based on this new regulation. If you happen to have referral sources without privileges and you just happen to compete with a hospital system - especially a hospital system that isn't a team player in the community, you could share a referral source NPI number and contact your Medicare payer questioning if they have paid for services at the hospital site. Selena Horner, PT ton, MI > > Good afternoon for those practicing in hospitals that see outpatients how is the new CMS interpretations affecting you if the doctor is not on staff of the hospital they can no longer refer to the hospital. I copied the language and the link below it was effective November 18, 2011. > > http://www.cms.gov/transmittals/downloads/R72SOM.pdf > > §482.56( Standard: Delivery of Services > Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital's medical staff to order the services in accordance with hospital policies and procedures and State laws. > Interpretive Guidelines §482.56( > Rehabilitation services must be ordered by a qualified and licensed practitioner who is responsible for the care of the patient. The practitioner must have medical staff privileges to write orders for these services. Privileges must be granted in a manner consistent with the State's scope of practice law, as well as with hospital policies and procedures governing rehabilitation services developed by the medical staff and approved by the governing body. Practitioners who may be granted privileges to order rehabilitation services include physicians, and may also, in accordance with hospital policy, be extended to Nurse Practitioners, Physicians' Assistants, and Clinical Nurse Specialists as long as they meet the parameters of this requirement. Although the following licensed professionals are also considered " practitioners " in accordance with Section 1842((18)© of the Social Security Act, they generally would not be considered responsible for the care of the patient or qualified to order rehabilitation services: Certified registered nurse anesthetist (Section 1861(bb)(2) of the Act); Certified nurse-midwife (Section 1861(gg)(2) of the Act); Clinical social worker (Section 1861(hh)(1) of the Act); Clinical psychologist (for purposes of Section 1861(ii) of the Act and as defined at 42 CFR 410.71); or registered dietician or nutrition professional. > > L. , PT, DPT, MBA > Director, Physical Rehabilitation Services > East Orange General Hospital > phone > fax > pager > " An ounce of prevention is worth a pound of cure. " > > > > __________________________________________________________ > IMPORTANT: This message contains confidential information and is intended only for the individual(s) named. > If you are not the named addressee, you are not authorized (either explicitly or implicitly) to disseminate, > distribute or copy this e-mail in any manner whatsoever. Please notify the sender immediately by e-mail if you > received this e-mail in error and delete this e-mail from your system. Unintended transmission shall not > constitute waiver of the attorney-client or any other applicable privilege. E-mail transmission cannot be > guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive > late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions > in the contents of this message, which arise as a result of e-mail transmission. > ________________________________ This message is intended for the sole use of the addressee, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the addressee you are hereby notified that you may not use, copy, disclose, or distribute to anyone the message or any information contained in the message. If you have received this message in error, please immediately advise the sender by reply email and delete this message. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 16, 2012 Report Share Posted January 16, 2012 I have owned a Private Practice and now I manage the Rehab Dept. of a large hospital. Our hospital system does not require our employed physicians to refer to the hospital's outpatient clinics. However, we do cultivate a culture around easing the way of our patient's through our multiple layers of care. We compete with private practices and physician owned practices just as you do. I am sure that not all hospitals operate like we do. That said, it seems that many who post on this list serve seem to be dividing our profession by labeling hospital outpatient systems as the enemy. That is painful given that many hospital Rehab Directors are quite active in the APTA, operate excellent practices that meet Joint Commission requirements ( which are very stringent and cost a lot resources to meet) and have to figure out ways to serve the uninsured. When I was in private practice, I had access to many contracts that the hospital systems in town could not get. In fact, the best contracts in town are not available to my hospital system but are available to private practitioners. This is just business. No one gets everything. Here in Oregon, our system is going to be part of an ACO. I envision that we will need some help in treating the extra 600,000 Oregonians that are going to become insured. Will the reimbursement be good? I don't think so. Will we need to come up with a new model to deliver care? I think so. Will that involve practices that are not a part of our system? I think so. However, we will choose carefully. Our average number of visits per patient is between 6 - 7. Our outcomes are great and our patients are satisfied. So, we will want to partner with practices that can match our outcomes and our average number of visits. I am hopeful that there will be many colleagues who will want to work with us. From: PTManager [mailto:PTManager ] On Behalf Of selenahorner Sent: Saturday, January 14, 2012 2:41 PM To: PTManager Subject: Re: outpatient referrals by nonstaff MDs Historically, hospital systems like to keep the gravy train going within their own system. From acute care to rehab to home health to outpatient services, the unwritten rule is to keep the patient within the hospital system, not for continuity of care as much as increased profits. Hospital systems are jumping on the ACO bandwagon and are buying out physician practices within surrounding communities. Generally speaking, hospital systems do have outpatient physical therapy satellites in communities. This means there isn't inconvenience to patients in various communities surrounding the large hospital headquarters. Reality... hospital systems have physicians who use hospital referral pads when making referrals. People who have this piece of paper in their hot little hands contact or choose from services on that sheet of paper. The choices on that sheet of paper only direct the hospital patients to hospital locations for services. It is completely unheard of for a hospital system to provide options outside of the system. It is also unheard of for that piece of paper to communicate freedom of choice for services. Hospital systems have monopolized this way for years without divulging facts & the freedom of choice to patients within their system. Hospital systems have a very large chunk of a population in any area who utilize services. Hospital systems monitor referral patterns. Private practices and freedom of choice have been ignored for years on this particular topic. I'm not for more and more regulations. I think it creates increased cost to verify medical staff privileges. Does this truly limit freedom of choice? Not completely. Remember, patients have the freedom to choose and that freedom isn't captured by any hospital system anyways because full disclosure doesn't occur in the real world. It forces hospital systems to grant every physician within their system medical staff privileges. Remember, the unwritten rule is to refer within the system. The only logical way to determine departmental impact of this - because really, you are all talking money and the loss of revenue - is to dig into your databases and analyze your top 25 referral sources. How many of those referral sources are not already within the hospital system? And... from that, how many of those currently within the hospital system do not have medical staff privileges? To understand the full " effect " of this, what's the data indicate? And, for those of you in private practice. Now would be a nice time to question your top referral sources and learn who has privileges where. You can educate them on their options for where to refer for physical therapy services based on this new regulation. If you happen to have referral sources without privileges and you just happen to compete with a hospital system - especially a hospital system that isn't a team player in the community, you could share a referral source NPI number and contact your Medicare payer questioning if they have paid for services at the hospital site. Selena Horner, PT ton, MI > > Good afternoon for those practicing in hospitals that see outpatients how is the new CMS interpretations affecting you if the doctor is not on staff of the hospital they can no longer refer to the hospital. I copied the language and the link below it was effective November 18, 2011. > > http://www.cms.gov/transmittals/downloads/R72SOM.pdf > > §482.56( Standard: Delivery of Services > Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital's medical staff to order the services in accordance with hospital policies and procedures and State laws. > Interpretive Guidelines §482.56( > Rehabilitation services must be ordered by a qualified and licensed practitioner who is responsible for the care of the patient. The practitioner must have medical staff privileges to write orders for these services. Privileges must be granted in a manner consistent with the State's scope of practice law, as well as with hospital policies and procedures governing rehabilitation services developed by the medical staff and approved by the governing body. Practitioners who may be granted privileges to order rehabilitation services include physicians, and may also, in accordance with hospital policy, be extended to Nurse Practitioners, Physicians' Assistants, and Clinical Nurse Specialists as long as they meet the parameters of this requirement. Although the following licensed professionals are also considered " practitioners " in accordance with Section 1842((18)© of the Social Security Act, they generally would not be considered responsible for the care of the patient or qualified to order rehabilitation services: Certified registered nurse anesthetist (Section 1861(bb)(2) of the Act); Certified nurse-midwife (Section 1861(gg)(2) of the Act); Clinical social worker (Section 1861(hh)(1) of the Act); Clinical psychologist (for purposes of Section 1861(ii) of the Act and as defined at 42 CFR 410.71); or registered dietician or nutrition professional. > > L. , PT, DPT, MBA > Director, Physical Rehabilitation Services > East Orange General Hospital > phone > fax > pager > " An ounce of prevention is worth a pound of cure. " > > > > __________________________________________________________ > IMPORTANT: This message contains confidential information and is intended only for the individual(s) named. > If you are not the named addressee, you are not authorized (either explicitly or implicitly) to disseminate, > distribute or copy this e-mail in any manner whatsoever. Please notify the sender immediately by e-mail if you > received this e-mail in error and delete this e-mail from your system. Unintended transmission shall not > constitute waiver of the attorney-client or any other applicable privilege. E-mail transmission cannot be > guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive > late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions > in the contents of this message, which arise as a result of e-mail transmission. > ________________________________ This message is intended for the sole use of the addressee, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the addressee you are hereby notified that you may not use, copy, disclose, or distribute to anyone the message or any information contained in the message. If you have received this message in error, please immediately advise the sender by reply email and delete this message. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 16, 2012 Report Share Posted January 16, 2012 I have owned a Private Practice and now I manage the Rehab Dept. of a large hospital. Our hospital system does not require our employed physicians to refer to the hospital's outpatient clinics. However, we do cultivate a culture around easing the way of our patient's through our multiple layers of care. We compete with private practices and physician owned practices just as you do. I am sure that not all hospitals operate like we do. That said, it seems that many who post on this list serve seem to be dividing our profession by labeling hospital outpatient systems as the enemy. That is painful given that many hospital Rehab Directors are quite active in the APTA, operate excellent practices that meet Joint Commission requirements ( which are very stringent and cost a lot resources to meet) and have to figure out ways to serve the uninsured. When I was in private practice, I had access to many contracts that the hospital systems in town could not get. In fact, the best contracts in town are not available to my hospital system but are available to private practitioners. This is just business. No one gets everything. Here in Oregon, our system is going to be part of an ACO. I envision that we will need some help in treating the extra 600,000 Oregonians that are going to become insured. Will the reimbursement be good? I don't think so. Will we need to come up with a new model to deliver care? I think so. Will that involve practices that are not a part of our system? I think so. However, we will choose carefully. Our average number of visits per patient is between 6 - 7. Our outcomes are great and our patients are satisfied. So, we will want to partner with practices that can match our outcomes and our average number of visits. I am hopeful that there will be many colleagues who will want to work with us. From: PTManager [mailto:PTManager ] On Behalf Of selenahorner Sent: Saturday, January 14, 2012 2:41 PM To: PTManager Subject: Re: outpatient referrals by nonstaff MDs Historically, hospital systems like to keep the gravy train going within their own system. From acute care to rehab to home health to outpatient services, the unwritten rule is to keep the patient within the hospital system, not for continuity of care as much as increased profits. Hospital systems are jumping on the ACO bandwagon and are buying out physician practices within surrounding communities. Generally speaking, hospital systems do have outpatient physical therapy satellites in communities. This means there isn't inconvenience to patients in various communities surrounding the large hospital headquarters. Reality... hospital systems have physicians who use hospital referral pads when making referrals. People who have this piece of paper in their hot little hands contact or choose from services on that sheet of paper. The choices on that sheet of paper only direct the hospital patients to hospital locations for services. It is completely unheard of for a hospital system to provide options outside of the system. It is also unheard of for that piece of paper to communicate freedom of choice for services. Hospital systems have monopolized this way for years without divulging facts & the freedom of choice to patients within their system. Hospital systems have a very large chunk of a population in any area who utilize services. Hospital systems monitor referral patterns. Private practices and freedom of choice have been ignored for years on this particular topic. I'm not for more and more regulations. I think it creates increased cost to verify medical staff privileges. Does this truly limit freedom of choice? Not completely. Remember, patients have the freedom to choose and that freedom isn't captured by any hospital system anyways because full disclosure doesn't occur in the real world. It forces hospital systems to grant every physician within their system medical staff privileges. Remember, the unwritten rule is to refer within the system. The only logical way to determine departmental impact of this - because really, you are all talking money and the loss of revenue - is to dig into your databases and analyze your top 25 referral sources. How many of those referral sources are not already within the hospital system? And... from that, how many of those currently within the hospital system do not have medical staff privileges? To understand the full " effect " of this, what's the data indicate? And, for those of you in private practice. Now would be a nice time to question your top referral sources and learn who has privileges where. You can educate them on their options for where to refer for physical therapy services based on this new regulation. If you happen to have referral sources without privileges and you just happen to compete with a hospital system - especially a hospital system that isn't a team player in the community, you could share a referral source NPI number and contact your Medicare payer questioning if they have paid for services at the hospital site. Selena Horner, PT ton, MI > > Good afternoon for those practicing in hospitals that see outpatients how is the new CMS interpretations affecting you if the doctor is not on staff of the hospital they can no longer refer to the hospital. I copied the language and the link below it was effective November 18, 2011. > > http://www.cms.gov/transmittals/downloads/R72SOM.pdf > > §482.56( Standard: Delivery of Services > Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital's medical staff to order the services in accordance with hospital policies and procedures and State laws. > Interpretive Guidelines §482.56( > Rehabilitation services must be ordered by a qualified and licensed practitioner who is responsible for the care of the patient. The practitioner must have medical staff privileges to write orders for these services. Privileges must be granted in a manner consistent with the State's scope of practice law, as well as with hospital policies and procedures governing rehabilitation services developed by the medical staff and approved by the governing body. Practitioners who may be granted privileges to order rehabilitation services include physicians, and may also, in accordance with hospital policy, be extended to Nurse Practitioners, Physicians' Assistants, and Clinical Nurse Specialists as long as they meet the parameters of this requirement. Although the following licensed professionals are also considered " practitioners " in accordance with Section 1842((18)© of the Social Security Act, they generally would not be considered responsible for the care of the patient or qualified to order rehabilitation services: Certified registered nurse anesthetist (Section 1861(bb)(2) of the Act); Certified nurse-midwife (Section 1861(gg)(2) of the Act); Clinical social worker (Section 1861(hh)(1) of the Act); Clinical psychologist (for purposes of Section 1861(ii) of the Act and as defined at 42 CFR 410.71); or registered dietician or nutrition professional. > > L. , PT, DPT, MBA > Director, Physical Rehabilitation Services > East Orange General Hospital > phone > fax > pager > " An ounce of prevention is worth a pound of cure. " > > > > __________________________________________________________ > IMPORTANT: This message contains confidential information and is intended only for the individual(s) named. > If you are not the named addressee, you are not authorized (either explicitly or implicitly) to disseminate, > distribute or copy this e-mail in any manner whatsoever. Please notify the sender immediately by e-mail if you > received this e-mail in error and delete this e-mail from your system. Unintended transmission shall not > constitute waiver of the attorney-client or any other applicable privilege. E-mail transmission cannot be > guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive > late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions > in the contents of this message, which arise as a result of e-mail transmission. > ________________________________ This message is intended for the sole use of the addressee, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the addressee you are hereby notified that you may not use, copy, disclose, or distribute to anyone the message or any information contained in the message. If you have received this message in error, please immediately advise the sender by reply email and delete this message. Quote Link to comment Share on other sites More sharing options...
Recommended Posts
Join the conversation
You are posting as a guest. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.