Orders for Outpatient Tests and Procedures: “What We Really Meant Was ….”

NAMSS and Horty Springer Jointly Present…

Orders for Outpatient Tests and Procedures: “What We Really Meant Was ….”

Live Webinar

Friday, May 4, 2012

1:00 – 2:30 p.m. EDT

Presented by

Susan Lapenta and Phil Zarone, Attorneys at Law, Horty, Springer & Mattern
Nancy Lian, Chair, NAMSS Industry & Government Relations Committee

In November 2011, the Centers for Medicare & Medicaid Services (CMS) Transmittal 72 sparked immediate confusion in the healthcare industry, as many interpreted it to mean that all providers writing orders for rehabilitation and respiratory care services had to be privileged by the hospital or clinic providing those services. In February 2012, CMS clarified its position in a new memorandum, explaining its intent to expand the categories of practitioners who could order rehabilitation and respiratory care services beyond physicians. Even with this clarification, there are still many questions.

Join Susan Lapenta and Phil Zarone of Horty, Springer & Mattern, and Nancy Lian of NAMSS, as they discuss how hospitals can create – or adapt – a written medical staff policy to reflect CMS’ rules.

You Will Learn

  • What services are affected and whether some service orders should be limited to members of the medical staff
  • What information the hospital must verify, who must verify it, and whether the information must be verified before the procedure is performed
  • Whether you must query the Data Bank
  • Whether you must check the excluded provider status for each ordering practitioner
  • How to verify that the ordering practitioner is “responsible for the care of the patient”
  • Whether your hospital is at risk for an enforcement action if it accepts orders for outpatient services without a policy that meets CMS requirements

Who Should Attend

All MSPs and healthcare attorneys who work with, or have questions about, CMS Transmittal 72 and its clarification are welcome to attend, including NAMSS members and non-members.


Webinar participants will receive 1.5 CE credits. Invite colleagues to view the webinar with you and they, too, can earn 1.5 CE credits! The cost per additional attendee is $10 for NAMSS members and $25 for non-members. Fill out the additional attendee form and submit to NAMSS.


NAMSS members: $125

Non-members: $175

To Register

Visit the NAMSS Online Store to purchase this webinar. Use Code HORTYSPRINGERCMS to receive the NAMSS member discount.