As 2012 begins,  everyday life seems to be getting more complicated.  Not only have the political  campaigns taken hold  of the airwaves-yes there is an election in 9 months;  the weather has many of us trying to choose  between shorts and parkas;  and as part of the regular day-to-day quality care practices,  Rehab providers strive to deliver optimal care in this increasingly complex environment. This month’s topic focuses on one of  CMS’s newly revised regulations designed to “improve service delivery”.

Sometimes- new  revisions  simply DO NOT  appear to that.

For example,  CMS  Transmittal 72 11182011 was released in November 2011 under no special circumstances or with any requests for comments. The transmittal  states that all orders for rehabilitation therapies both inpatient  and outpatient must be written by a practitioner aka doctor or nurse practitioner  who is a part of the  hospital staff where the patient is to be treated.  On inpatient- this is not a big deal. It actually  works, when patients receive care in a hospital,  every doctor  who delivers care in that space is a part of  the staff.  Even if the patient came from another state, that new patient will  become  part of the admitting doctor’s service and be under her care for orders.

BUT on outpatient, the interpretation and implementation of this transmittal can be  VERY BIG deal…so let’s consider a real life situation  and analyze that.

For a patient who has received special hospitalization in other city, county or even state, the special therapy orders written  by the discharging doctor  would not be valid at the patient’s local hospital. Like a person who suffers a spinal cord injury while driving from SC to Florida,  is injured in Atlanta and receives care at the special rehab spinal cord center in Georgia.

Once the discharge plans were set,  the patient going back home to SC would have to see the  hospital staff doctor in SC to get new orders to be treated at the local hospital in his hometown town.  Probably- not too quickly either- you know how long it can take to get a non-emergency appointment….plus there is that additional financial cost of co-payments  plus  the real effort for  the patient and family in arranging an additional trip to the new “hospital” doctor.  Clinically, the first doctor knew the patient and his history and wrote the outpatient treatment orders based on those needs;  but the new doctor must start at the beginning….maybe giving similar orders- BUT may not.

Maintaining  quality care and improving access are concepts regularly stated by CMS.   We are just not sure this transmittal’s regulations meets those two goals…what do you think?

AMPRA is actively monitoring the next steps from CMS and the  response from the Rehab industry on Transmittal 72111802011.  If your organization has  have you been affected by this practice – Please contact AMPRA.

Looking to learn more about regulations, quality care and how to positively  impact  your organization- BRB Consulting would welcome hearing from you. Contact us today.

 

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