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The power of the people...clearly this change from CMS reflects what is right with the world- okay maybe not the whole world, but certainly the World of Rehab! After extensive communication and outreach by numerous professional organizations including AMRPA, APTA, AOTA and more, CMS recognized some of the inherent problems with Transmittal 72. After significant efforts from the Rehab community and individuals who would be effected by the suggested change, CMS listened!
On February 17, 2012 , CMS rescinded the information and implemented the language below.
Orders for outpatient services (as well as patient referrals for hospital outpatient services) may be made by any practitioner who is:
- Responsible for the care of the patient;
- Licensed in, or holds a license recognized in the jurisdiction where he/she sees the patient;
- Acting within his/her scope of practice under State law; and
- Authorized by the medical staff to order the applicable outpatient services under a written hospital policy that is approved by the governing body. This includes both practitioners who are on the hospital medical staff and who hold medical staff privileges that include ordering the services, as well as other practitioners who are not on the hospital medical staff, but who satisfy the hospital’s policies for ordering applicable outpatient services and for referring patients for hospital outpatient services.
The CMS Memo on Hospital Outpatient Rehab – February 17 2012 (click to view PDF version) supersedes the guidance for §482.56(b) (Tag A-1132) and §482.57(b)(3) (Tag A-1163) found in SC-11-28 (May 13, 2011) and State Operations Manual (SOM) Transmittal #72 (November 18, 2011).
The new guidance evidences the importance of access and that quality care remain principals upon which CMS seeks to ensure the delivery of provider services. This revised language reinforces these concepts, assuring ongoing rights for individuals in need of rehab.
As providers and recipients of care, it is reassuring to know- that with enough coordinated efforts, change can and does happen – even in CMS.
Way to go Rehab!
To learn more about managing change in your organization,
contact BRB Consulting today.