Surviving Survey and Re-certification - PowerPoint PPT Presentation

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Surviving Survey and Re-certification

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Title: Surviving Survey and Re-certification


1
Surviving Survey and Re-certification
  • By Joanie Perkins, CPC

2
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
3
Objectives
  • How to decide if youre eligible for RHC
    designation
  • Know when youre due for an announced or
    unannounced survey
  • Know what to expect from your surveyor
  • Know the conditions for certification and how to
    meet them

4
Conditions of CertificationRegs published 78
  • 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

5
Location of Clinic (42 CFR491.5)
  • The clinic must be located in a non-urbanized
    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

6
Know this guy?
7
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

8
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

9
The Buck Stops Here
10
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

11
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.
  • RHCs must have a back up in case the mid-level
    or medical director take any type of leave for
    any duration.

12
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

13
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

14
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.

15
Physician Responsibilities
  • Must provide and document oversight for mid-level
  • 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
    NPs records for prescriptive authority
    100 review PAs

16
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.

17
Provision of Services
18
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

19
Provision of Services (42 CFR 491.9)
  • Policies must include
  • Description of services provided and provided
    through arrangement
  • Guidelines for medical management which include
  • Conditions requiring referral/consultation
  • Maintenance of health records
  • Periodic review of services furnished
  • Storage/Handling of drugs and biologicals

20
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 physicians
    office
  • Six lab tests
  • U/A
  • Hbg or Hct
  • Blood sugar
  • Fecal occult blood
  • Pregnancy
  • Primary culturing for transmittal to a certified
    lab

21
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

22
Medical Records
23
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.

24
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

25
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

26
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

27
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

28
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.

29
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