Surviving Survey and Re-certification

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Surviving Survey and Re-certification

• By Joanie Perkins, CPC

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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
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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

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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

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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

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Know this guy?
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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

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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

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The Buck Stops Here
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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

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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.

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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

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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

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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.

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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

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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.

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Provision of Services
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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

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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

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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

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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

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Medical Records
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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.

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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

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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

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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

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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

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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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Questions?