Is Your Physician Putting You Out of Compliance?

Is your physician putting you out of compliance by not visiting their patients timely?  It’s pretty common for nursing homes to have to remind their docs several times that it’s time to see their nursing home patients.  Many physicians get so busy with their own practices, they simply put the nursing home on the back burner.

This is something you must keep on top of.  Usually, this task is assigned to the Medical Records Director who keeps a schedule of when the visits are due as well as when Medicare certifications are due.  Per F387, the resident must be seen by a physician at least once every 30 days for the first 90 days after admission, and at least once every 60 days after that.  The regs do grant a 10 day grace period, so if the physician is up to 10 days late, you’re still in compliance.

The 10 day grace period does not, however, push the timeline for the next visit’s due date.  It’s stays on the original schedule of every 30 days for 90 days after admission, then every 60 days thereafter.

The words “Must be seen” means the physician must actually make face-to-face contact with the resident.  I have seen a physician come in, open a chart, and start writing a progress note without ever seeing the resident.  It didn’t go over very well with me and didn’t go very well with the physician when I called him out on it.  Hold your physicians accountable.

The regulations allow, after the initial visit, for the physician to delegate every other vist to their physician assistant, nurse practitioner, or clinical nurse specialist; so, you may see the physician on one vist and their nurse practitioner the next – alternating going forward. You’re still in compliance.

The regs on physician visits do not relieve the physician from visiting the facility when the resident’s condition deems it necessary; though, many times, the physician will issue an order to send to the hospital if a resident has a serious decline.  These unplanned discharges must also be monitored to ensure they are appropriate discharges.  Unplanned hopsital discharges can kill your census.

Watch the physician visits and keep your facility in compliance.  If necessary, take the bull by the horns and speak to your physicians on ensuring timely visits.  Let them know the facility is glad to send reminders, but they must do their part in order to continue to see your nursing home patients.

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