CMS Regulations about NPs signing orders

[CapeCodMermaid, RN]

We just received a letter from one of the local medical groups stating it is against their policy for NPs to verify admission orders, and, per CMS policy, new admission orders must be verified by an MD.

We've been having the admission orders verified by NPs for years.

Does anyone know is this is a new regulation? Or can anyone (and that means you TALINO)

point me in the direction to find the reg?

Thanks.

[Talino]

http://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/som107ap_pp_guidelines_ltcf.pdf physician services pp 505-511

i am uncertain what "verify" entails. however, the initial face-to-face contact and all orders for the immediate care on admission must be performed by a physician only. subsequent visits, at the physician's option, maybe delegated to nps.

483.40(e) physician delegation of tasks in snfs

(1) except as specified in paragraph (e)(2) of this section,a physician may delegate tasks to a physician assistant, nurse practitioner, or clinical nurse specialist who--

(i) meets the applicable definition in 491.2 of thischapter or, in the case of a clinical nurse specialist, is licensed as such bythe state;

(ii) is acting within the scope of practice as defined bystate law; and

(iii) is under the supervision of the physician.

(2) a physician may not delegate a task when the regulations specify that the physician must perform it personally, or when the delegation is prohibited under state law or by the facility's own policies.

483.40(f) performance of physician tasks in nfs

at the option of state, any required physician task in a nf (including tasks which the regulations specify must be performed personally by the physician) may also be satisfied when performed by a nurse practitioner, clinical nurse specialist, or physician assistant who is not an employee of the facility but who is working in collaboration with a physician.

[CapeCodMermaid, RN]

Thanks. I guess I've been breaking the rules for years. We usually have the NPs okay the admission orders.

[Talino]

thanks. i guess i've been breaking the rules for years. we usually have the nps okay the admission orders.

when you say "okay", does the np do the initial physical exam and write the admission orders or simply rewrite the "physician's orders" as per facility's policy?

as i previously pointed out in this thread ...

interpretive guidelines 483.40©

"must be seen" means that the physician must make actual face-to-face contact with the resident. there is no requirement for this type of contact at the time of admission, since the decision to admit an individual to a nursing facility (whether from a hospital or from the individual's own residence) generally involves physician contact during the period immediately preceding the admission.

nps rewriting the orders to affirm a physician's order to admit is not forgoing the "must be seen" requirement.

[CapeCodMermaid, RN]

We call them, read them the orders received from the discharge summary. They say yes or change some of the orders. The physician still has to see them within 48 hours.