Traditionally TJC surveyors have generally NOT looked for privileges for physicians who order therapy in outpatient rehabilitation centers. CMS just released in the November COP release. Note that if the hospital bills for the outpatient rehabilitation center under the hospital CCN, it is both surveyable, and CMS would expect privileges to be granted. I have asked John Herringer if TJC surveyors will look for this. I will update the blog when I get his response.
(Rev. 72, Issued: 11-18-11, Effective: 11-18-11, Implementation: 11-18-11)
§482.56(b) Standard: Delivery of Services
Services must only be provided under the orders of a qualified and licensed practitioner who is responsible for the care of the patient, acting within his or her scope of practice under State law, and who is authorized by the hospital’s medical staff to order the services in accordance with hospital policies and procedures and State laws.
Interpretive Guidelines §482.56(b)
Rehabilitation services must be ordered by a qualified and licensed practitioner who is responsible for the care of the patient. The practitioner must have medical staff privileges to write orders for these services.
This is the reply from John Herringer at SIG
For rehab if this is a new CMS requirement then the practitioner will need to be privileged. We have always required privileging for any outpatient services requiring medication administration or blood administration as required by CMS. It was not required for diagnostic testing and previously not for therapy services. The requirement would apply to any setting included in the scope of the hospital survey.