Transcript Surviving Survey and Re-certification

Surviving Survey and Recertification
By: Joanie Perkins, CPC
Face your deficiencies and
acknowledge them; but do not let
them master you. Let them teach you
patience, sweetness, insight.
Helen Keller (1880 – 1968)
American Writer
Objectives
• How to decide if you’re eligible for RHC
designation
• Know when you’re due for an announced
or unannounced survey
• Know what to expect from your surveyor
• Know the conditions for certification and
how to meet them
Conditions of Certification
Regs published ‘78
1. Compliance with Federal, State and
Local Laws (42 CFR 491.4)
a.) Licensure of clinic
b.) Licensure, certification or registration of
personnel
c.) State law supersedes Federal Law on who
can provide services
Location of Clinic (42 CFR491.5)
• The clinic must be located in a nonurbanized area that is designated as a
shortage area, and may be a permanent
or a mobile unit.
– Each RHC will be considered independently
– Mobile Units need to have fixed scheduled
locations which meet the rural and shortage
area designations
– Your regional office will make this
determination
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Physical Plant and Environment
(42 CFR 491.6)
• Construction
– Maintained to ensure access and safety of
patients and adequate space
• Maintenance
– Equipment is in safe operating order
– Drugs and Biologicals are appropriately
stored
– Premises are clean and orderly
Physical Plant and Environment
(42 CFR 491.6)
• Emergency Procedures
– The clinic assures the safety of patients in
case of non-medical emergencies by:
• Training Staff
• Exit signs
• Taking other appropriate measures that are
consistent with the area the clinic is located
The Buck Stops Here
Organizational Structure (42 CFR
491.7)
• Basic Requirements
– The clinic is under the medical direction of a
physician, and staffing meets the mid level
requirement
– Clinic has clear lines of authority in writing
• Disclosure
– Name/Address
– Clinic Administrator
– Medical Director
Staffing and Staff
Responsibilities (42 CFR 491.8)
• One or more Physician and/or NP, PA
must be available to furnish services at all
times the clinic operates as an RHC.
– Indiana surveyor stated the following:
• Inadequate staffing is the most common citation
RHC surveyors give out.
• RHC’s must have a “back up” in case the midlevel or medical director take any type of leave for
any duration.
Staffing and Staff
Responsibilities (42 CFR 491.8)
• A provider must be on site to perform services
during all times RHC operates
• RHC's may allow beneficiary entry to the waiting
room or other non-patient care areas
to handle billing inquiries or to get out of the
weather when the mid-level practitioner as
defined in §493.2, clinical social worker, clinical
psychologist or physician member of the staff is
not present under the following circumstances:
Staffing (CFR 491.8) Cont
• Solely for administrative purposes or to
allow patients to get out of inclement
weather
• No health care services may be provided
• Administrative hours should be posted
• State Law supersedes this regulation if it
does not allow patients in the building
Staffing and Staff
Responsibilities (42 CFR 491.8)
• Physician and mid-level must participate
jointly in the development of new policies.
Each staff member must review, agree
with and adhere to clinic policies. There
should be sufficient written documentation
that this is carried out.
Physician Responsibilities
• Must provide and document oversight for midlevel
• Must provide direct care services in the RHC
• Must spend “sufficient time” at a minimum of
once every two weeks to discharge their duties.
– Indiana Regulations require 5% review weekly of
NP’s records for prescriptive authority
100% review PA’s
Mid-level Responsibilities
• Participate in development, execution and
review of written policies
• Provide services in accordance with those
policies
• Arrange for referrals as needed
• Assure that adequate health records are
maintained and transferred as required when
patients are referred
• Participate with physician in a periodic review of
health records.
Provision of Services
Provision of Services (42 CFR
491.9)
• The clinic must be primarily engaged in
providing outpatient health services
• Patient Care Policies
– Services must be furnished in accordance
with written policies that are consistent with
State law
– Policies must be developed with a group of
professional personnel that include a
physician, mid-level and someone that is not
a member of the clinic staff
Provision of Services (42 CFR
491.9)
• Policies must include
– Description of services provided and provided
through arrangement
– Guidelines for medical management which
include
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Conditions requiring referral/consultation
Maintenance of health records
Periodic review of services furnished
Storage/Handling of drugs and biologicals
Provision of Services (42 CFR
491.9)
– Policies must be reviewed annually by a group of
professional personnel
• Direct Services
– Services typically provided in a physician’s office
– Six lab tests
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U/A
Hbg or Hct
Blood sugar
Fecal occult blood
Pregnancy
Primary culturing for transmittal to a certified lab
Provision of Services (42 CFR
491.9)
• Emergency
– Life saving drugs/biologicals
• Analgesics, anesthetics (local), anticonvulsants, antidotes
and emetics, serums and toxins
• Services provided through agreements or
arrangements
– Inpatient hospital care
– Physician services in NH/hospital patients
home/office
– Additional diagnostic laboratory
Medical Records
Patient Health Records (42 CFR
491.10)
• Records must be kept in accordance with
written policies
• A staff member must be designated as
responsible for the records and ensuring
they are accurate, readily accessible and
systematically organized.
Patient Health Records (42 CFR
491.10)
• Records must include
– ID and social data, consent forms, medical
history, health status, health care needs,
summary of visit, disposition and instructions
to the patient.
– Reports of physical exams, diagnostic lab test
results, consults
– Physician orders, reports of treatment and
medications
– Signatures
Patient Health Records (42 CFR
491.10)
• Protection of record information
– Maintains confidentiality
– Safeguards against loss, destruction or
unauthorized use
– Written policy governing the use and removal
of records and release of information
– Patients written consent is required for
release of information
• Retention – 6 years
Program Evaluation (42 CFR
491.11)
Annually the evaluation must include:
Utilization of clinic services (at least
the number of patients served) and
number of total visits
A review of both active and closed
medical charts (10 open 5 closed)
A review of the policy and procedure
manual
Program Evaluation - (42 CFR
491.11)
• Surveyors will decide if the services you
provided were:
– Appropriate
– In alignment with your current policies
– If any changes are necessary
QAPI Program 491.11
• a Rural Health Clinic must have a Quality
Assessment and Performance
Improvement (QAPI) program that is
appropriate for the complexity of its
organization and services and focuses on
maximizing outcomes by improving
patient safety, quality of care, and patient
satisfaction.
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