CMS Issues
Final Rule on 4 CoPs
Audio CD
Recorded December 20,
2006
1:00 - 2:30pm ET
Faculty: Linda
Haddad, LeeAnne Mitchell & Ian Donaldson
On November 27, CMS issued a final
rule on four CoPs that were proposed in March 2005. This final
rule revises and updates the CoPs requirements for: "Completion
of the history and physical examination in the medical staff
and the medical record services CoPs; authentication of verbal
orders in the nursing service and medical record services CoPs;
securing medications in the pharmaceutical services CoP; and
completion of the postanesthesia evaluation in the anesthesia
services CoP."
These
new CoPs are effective January 26, 2007. What do you
do when there's a conflict between the CoPs, JCAHO Standards
and state licensing regulations?
Join Linda
Haddad, LeeAnne Mitchell-O'Brien and Ian Donaldson on December
20 for a discussion of these new requirements, including the
following:
H&Ps
The new COPs allow
a medical history and physical examination to be completed no
more than 30 days before or 24 hours after admission for each
patient.
- Can a hospital rely
on an H&P
done by the patient's primary care physician in the office?
What if the primary care physician does not have privileges
at the hospital?
- Who
can do an H&P?
- Do
the H&P requirements apply
to outpatient as well as inpatient admissions?
- When is an update note required?
Verbal Orders
The new CoPs require all orders,
including verbal orders, to be dated, timed and authenticated
promptly by the prescribing practitioner or another practitioner
who is responsible for the care of the patient.
- When are verbal orders
appropriate?
- Are
hospitals required to implement a "read-back" verification process when using verbal orders?
- Who
may authenticate verbal orders? May a physician assistant
or nurse practitioner authenticate a physician's verbal order?
- What are the time limits for authentication
of orders?
Securing Medications
In the preamble to the new rules,
CMS stated that the revisions regarding securing medications
were made "in response to concerns expressed by the medical
community related to carts containing medications as well as
medications kept at the patient's bedside."
The new rules state
that "all drugs
and biological must be kept in a secure area, and locked when
appropriate." Controlled substances must be kept locked in a
secured area and only authorized personnel may have access
to locked areas.
- Who are "authorized personnel"?
- What
is a "secure area"?
- Is patient self-administration
of drugs acceptable?
Completion of
Postanesthesia Evaluation
The new rules require "with respect
to inpatients, a postanesthesia evaluation [to be] completed
and documented by an individual qualified to administer anesthesia
within 48 hours after surgery."
- Is a postanesthesia
evaluation required for conscious sedation?
- Is
a postanesthesia evaluation required for nonsurgical procedures?
- What
if the patient is discharged less than 48 hours after the procedure?
- Can a physician delegate a postanesthesia
evaluation to a physician assistant?
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