Prior to providing care, treatment, and services, the hospital obtains or renews orders (verbal or written) from a licensed independent practitioner.
Sounds like a no-brainer right? How difficult can it be for hospitals to comply with such a simple standard?
Turns out, pretty difficult.
Nearly every hospital struggles to comply with at least one aspect of that simple-sounding CMS/Joint Commission requirement in today’s highly-mobile society.
Each day around the country, patient’s show up at hospitals wth orders for various laboratory or radiology studies. If the physician or advanced practice nurse practices at the hospital, there’s no question that he or she is a licensed independent practitioner; the records are right there, usually available with just a few keystrokes.
But what if the doctor or APN practices at a hospital across town, or across the country? Patient’s often travel with prescriptions in hand, or may contact their health care provider back home regarding a flare-up of some chronic condition. Studies are ordered, and results need to be sent to the ordering practitioner.
How does the hospital performing the study verify that the orders originated with a licensed, independent practitioner? Before the lab work, radiology exam, or other outpatient study can be completed, someone at the hospital must obtain an address, verify the license of the ordering practitioner in the state in which they practice, and record that information in the hospital data system. In large cities or popular tourist areas, that scenerio can be repeated many times each day.
Some health systems have hired dedicated empoyee(s) to handle this responsibility, others pass the job on to staff in Patient Admissions or Registration, usually with the Medical Staff Office as a back-up resource if questions or problems arise. Because the verification must take place pror to the provision of services, meeting this standard in a timely fashion can prove quite challenging.
The complete standard is referenced below:
The hospital provides care, treatment, and services as ordered or prescribed, and in accordance with law and regulation.
Elements of Performance for PC.02.01.03
1. For hospitals that use Joint Commission accreditation for deemed status purposes: Prior to providing care, treatment, and services, the hospital obtains or renews orders (verbal or written) from a licensed independent practitioner in accordance with professional standards of practice and law and regulation.
Reference Cop: 42 CFR 482.12(c) Governing Body