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outpatient referrals by nonstaff MDs

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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(B) 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(B)

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(B)(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. "

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