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Re: JCAHO & OP Orders

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Mark -

Congratulations! Now you, your staff, your administrator, and the other

department

managers may sleep! Very small, rural facilities, especially without a

physiatrist, are tremendous places to practice.

Since JCAHO requires hospital governing bodies and medical staffs to control all

of

the activities within their facilities, it is not uncommon for them to want to

address referrals from non-staff (much less, out of state) physicians.

I have known of local medical staff chiefs who would write a parallel " scrip " to

cover the institution, but that could easily change, since physicians' ordering

habits are being profiled by tracking the UPIN number. ...Or, if the non-staff

doc

from the big city far away has requested something really wierd.

Where hospitals wish to be *the* source for services, they will need to find

creative yet ethical ways of dealing with this issue.

How would JCAHO handle patients who are seen under direct access? (Treatment

without referral)

Dick Hillyer

Hillyer Associates, Inc.

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Guest guest

Mark and Dick,

I am curious which JCAHO standard they use in order to force facilties to

use only their own privileged staff for referrals. With outpatient P.T.

clinics from all facilities taking contracts with large insurers (in urban

areas), it is almost guaranteed that they will receive referrals from

non-privileged physicians. Does anyone know the standard number in the

JCAHO manual?

Mark Dwyer, MHA, PT

Kansas City, Kansas

mdwyer1@...

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Guest guest

Mark:

The issue is not really " staff " versus " non-staff " but one of how you

verify licensure and competency of the physician referring. You have

several options:

1. If you have a medical director (it does not have to be a physiatrist);

that individual could co-sign for the non-staff physician. The problem

with this is that if the director does not personally know the referring

doc, he or she might be concerned about liablity.

2. Your hospital could consider an additional level of staff privileges;

" courtesy " or " referral for outpatient testing and treatment only "

privileges; in these cases, you could set up a mechanism to verify, at

minimum, the physician's licensure and training. Your medical staff office

should be able to help you. You can get the need information from AMA for

a fee of $12/doc. If you go this route, be sure to do some type of annual

or biannual review on the courtesy group and be sure to keep you files up

to date.

This question usually comes to light related to outpatient test (lab/xray)

being performed on orders from non-staff physicians. You may see if your

medical staff office has a system for dealing with this or if you want to

have your facility deal with all possible issues at once. If you already

have a system for testing you could add your other referral sources to the

same group.

Quite frankly, I'm surprised that they made an issue of this for your

department since the physician never touches the patient in your

department. However, I recently got a written opinion from JCAHO that a

consultant radiologist who reads films off site does not have to be

credentialled; we credentialled anyway and luckily so since our surveyor

disagreed with the written opinion. The fact that you got just a

" consultative " recommendation is probably fair warning for all of us that

this is an area that will now be looked at.

Angie , PT

Amarillo, TX

At 10:19 AM 7/19/98 -0500, you wrote:

>Greetings,

>

>We have just completed a JCAHO survey and Rehab got a " gold star " , except

that

>the issue of accepting non-staff physician orders came up. Apparently,

>unbeknownst to me, JCAHO requires hospital-based PTs to accept ONLY orders

from

>privileged staff docs despite " open practice " in Minnesota (this is unique to

>*hospital-based* departments). Our policy, approved by our medical staff, is

>that in-state orders are accepted within 6 months of writing (State law is 12

>months). We are a very small, rural facility without a physiatrist.

>

>(We ended up not getting cited but will likely be told to correct this for

the

>next survey ... )

>

>Anyone have any experience with this?

>

>Thanks in advance.

>

>Mark

>

>--

>Mark R Eliason, PT

>meliason@...

>Apple Valley, Minnesota, USA

>

>

>

>

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Guest guest

Mark, Dick and Angie,

Thanks for your replies.

The standard discussed during one of the morning conferences that related to the

PT orders issue was MS.5.14 ... " All individuals who are permitted by law and by

the hospital to provide patient care services independently in the hospital have

delineated clinical privileges, whether or not they are medical staff members. "

Also, another related standard, MS.6.5, states, " Management of each patient's

care is the responsibility of a qualified licensed independent practitioner with

appropriate clinical privileges. "

To be honest, I spent exactly no time studying the medical staff privileging

section of the manual prior to the survey. But frankly, even if I had read

those standards thoroughly, I would not have interpreted them to say that

outside physicians could not refer to our PT outpatient clinic. The issue was

mentioned during the survey of our department, but was not mentioned during the

exit conference, so we'll have to wait for the final report to see what the

specific reference is.

He was specific in saying that the standard ONLY applied to hospital-based

practices (staff PTs), so presumably, contract agency staffed services MAY not

be held to the same standard (?????).

Mark, your point about contracts with large insurers is well-taken, and I don't

know what the JCAHO interpretation would be.

Dick, my GUESS is that JCAHO doesn't recognize direct access within a hospital

staff. This gets back to the definition (community standard) of " independent

practitioner " , doesn't it?

Angie, we have a method of verifying current MD licensure through our state

board (free, BTW) but this was presented as a " staff vs non-staff " issue.

Granting temporary or limited privileges isn't practical since this is usually a

one-shot-deal from docs all over the state.

Thanks for the insight. I certainly welcome further comments.

Take care,

Mark

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Mark R Eliason, PT

meliason@...

Apple Valley, Minnesota, USA

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Guest guest

We just completed our survey in land. We had heard of this standard from

JCAHO but it did not come up in our survey. We also heard it is still very

controversial at JCAHO. We were prepared to use direct access as an argument.

Clearly it is unrealistic to expect a hospital to credential all referral

sources for PT. It is ultimately up to the PT to determine the delivery of

services and having the PT as staff should be adequate.

JCAHO did focus heavily on age specific competencies - the old written test

doesn't work, you need more, ie observation. Also on the provision of the

same level of care for all patients regardless of admission date - that means

7 day availability, a triage system is allowed.

Kris Edgar, PT

Civista Health

LaPlata, MD

301/609-4290

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Guest guest

Thanks, Kris

You wrote:

> JCAHO did focus heavily on age specific competencies - the old written test

> doesn't work, you need more, ie observation. Also on the provision of the

> same level of care for all patients regardless of admission date - that means

> 7 day availability, a triage system is allowed.

>

You are exactly right about the age specific compentencies. Our only " ding " was

because 4 out of 80 reviewed personnel charts did not demonstrate the " motor "

component of age specific compentency, although the cognitive component was

adequately demonstrated. Some sort of observed, active compentency

demonstration apparently must be documented.

We responded to the 7 day availability issue (it WAS specifically asked) with

the " triage " strategy and an on-call system where a PT is always available by

pager. We only have 2 PTs so this was entirely adequate from the surveyors'

perspective, recognizing that staffing 365 days with on-site staff is impossible

and still maintain availability for extended hours outpatient coverage (we also

cover from 6a-6p for OPs, as needed).

Thanks to all for your comments.

Mark

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Mark R Eliason, PT

meliason@...

Apple Valley, Minnesota, USA

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Guest guest

Kris,

> JCAHO did focus heavily on age specific competencies - the old written

test

> doesn't work, you need more, ie observation. Also on the provision of

the

> same level of care for all patients regardless of admission date - that

means

> 7 day availability, a triage system is allowed.<

Regarding your comments above, what are you using to show age-related

competencies? Currently we do many inservices and workshops that involve

adults and geriatric patients. We see almost no pediatrics, but as with

any PT clinic located in a hospital, the chance is there that we will get a

four year old gait trainer or some other such thing. Therefore, we still

have to show age related competencies for peds patients. We have done one

inservice per year from a PT/OT that works in a pediatric setting. Will

that do? Is has been sufficient in the past.

Also, your comment about " same level of care for all patients regardless of

admission date. " What exactly were you referring to and what JCAHO

standard does it address (if you know)? I am curious about this one and

have heard that it is being brought up more and more.

By the way, a sister hospital here in town just went through JCAHO and

nothing was mentioned about outpatient referrals from non-privileged docs.

As usual, it seems to depend on the surveyor more than the standards.

Mark Dwyer, MHA, PT

Kansas City, Kansas

mdwyer1@...

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Guest guest

Mark,

For competencies, our surveyor liked a " mixed media " . Inservices, continuing

education, direct observation, mock situations. The key was to assure the

staff are competent. We talked a lot about the difference in evaluative vs

treatment competencies - ex, is the risk of osteoporosis taken into account

when developing an exercise program. I felt the bottom line was to have

something documented to show we pay attention to it.

About the same level of service - I was asked for the treatment schedule of a

total hip who had surgery on a Monday and for one who had surgery on a Friday.

The right answer was that they would both begin bid visits on post-op day one

and continue daily until discharge. The other component was the availability

of a PT for weekend assessments considered priority. We have established a

triage system for on-call. The biggest for us is actually in Speech for

dysphagia assessments. I don't know the exact standard, but it is a point of

emphasis this year.

Hope this helps,

Kris Edgar,PT

Civista Health

LaPlata,MD

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Guest guest

Mark,

Our survey focused mostly on PT availability. I was able to plead scarce

resources for Speech. The standard states the same level of care for all

patients regardless of day of admission. We do bid for THR and TKR on Sat and

an extended qd on Sunday. We didn't have to get real detailed in the survey.

The golden rule of just answer the question you are asked worked well. We

were only asked about days, not frequency - so I didn't volunteer any more

detail.

Actually, our Orthopedists are more vocal than JCAHO on thus matter. For them

it applies to acute and sub-acute units. They do surgery at 3 local

hospitals, so it is to our benefit to make them happy.

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