Guest guest Posted January 19, 2012 Report Share Posted January 19, 2012 The intent of my post wasn't to divide. I figured someone needed to step up and discuss a bit of reality with how referrals occur. How that referral pattern is " cultivated. " Hospital systems do have a gravy train of referrals. The focus of this regulation is referrals (nothing more, nothing less). The topic of my post was focused on referral pathways (for lack of a better word). No one has shared any data on the actual impact of this particular regulation. Most posting have had a " knee jerk " reaction. I took some time the other day and called 4 physician offices who tend to refer to my private practice. I wanted to know where the primary care physicians had hospital privileges, if any. Amazingly, all the physicians in all 4 offices had privileges in both competing hospitals in my local area. One physician office employs primary care physicians within a branch of their hospital system. Those physicians also had privileges within the competing hospital system. Most of the orthopaedic surgeons who refer to my private practice have scheduled times in the operating rooms of both hospitals AND they also are on call via their schedule at both hospitals. I didn't call any of those offices because common sense prevails that they all have privileges at both competing hospital systems. It isn't appearing to me that this " new " interpretation of a regulation that was in effect in 2008 http://www.cms.gov/Transmittals/Downloads/R37SOMA.pdf will truly affect access to care or truly substantially reduce freedom of choice. The bulk of referrals will come from local physicians/surgeons. In the event a prospective, local patient travels to say the Mayo Clinic and your local citizen requires physical therapy services and the referral source doesn't have privileges in the hospital system, are you telling me you wouldn't just call the primary care physician who highly likely has privileges in your hospital system, explain the situation... send a plan of care to both the referring physician and the primary care physician and have both signed signatures in the chart? 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 23, 2012 Report Share Posted January 23, 2012 Would it be helpful to consider having different levels of credentialling? This would necessitate a By- Laws change, probably. Sally -McNamara, MCS,CCC-SLP;CCP;CCE Compliance Consultant (-in Ohio at the moment) Sent from my Verizon Wireless BlackBerry Re: gravy train? Selena, I think you may be underestimating the impact of this. My pediatric therapists see patients from a very large area and many of their physicians do not have privilages at our hospital. Their local pediatrician are probably not going to be comfortable writing the script for these children's special needs. We also have 2 hospitals in our community. Some physicians are only credentialed at one of the hospitals, but the patient may chose our services over the other hospital because of specialization of our therapists, insurance, or other reasons. Again, I cannot just call another physician that is credentialed and ask for another script. We also have several clinics in rural areas that the physicains working in those areas are not credentialed at our hospital, but do use our outpatient clinics for services. Again, just calling another physician is not an option. Plus I don't know of many physicians that would be willing to write scripts for a patient they have not seen. Kathy berger, P.T. Manager of Physical Therapy Services Mercy Medical Center > > > > > > 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.