Re: outpatient referrals by nonstaff MDs

[Guest guest]

Well Dave, in view of the fact that the National Defense Authorization Act

s.1867 was recently passed in violation of Posse Commitatus and the 6th and

7th Amendments of the Constitution of the United States with nary a whisper

of protest from the American sheeple, I'd say the answer to your question is

yes.

The sad thing is that no matter what is done to stay in compliance with

whatever comes down the pike, the regulations and requirements will become

progressively more complex and onerous and the bar will be raised

progressively higher and higher until, at some point in the future, it will

become nigh on impossible to remain 100% in compliance with all the rules

and regulations laid down in the many tens of thousands of pages that no one

who is attempting to live a normal life can possibly have the time to read,

much less understand. At that point, enforcement can be used as a selective

tool to reward " friends " and punish " enemies " and cattle prong the herd it

wherever direction the controllers want it to go. If you don't think, this

can happen, think again. It's already happening with the SEC and the CFTC.

Welcome to regulatory capture in the corporatocracy.

, PT, OCS

outpatient referrals by nonstaff MDs

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

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" An ounce of prevention is worth a pound of cure. "

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