Q:

We have a physician who has requested that all patients be seen in her office rather than on-site at the facility. Will this satisfy the physician visit requirements?

 

A:

The regulations do not specifically address a location requirement; however, according to the State Operations Manual:

      • It is expected that visits will occur at the facility rather than the doctor’s office unless office equipment is needed or a resident specifically requests an office visit. If the facility has established policy that residents leave the grounds for medical care, the resident does not object, and this policy does not infringe on his/her rights including the right to privacy, there is no prohibition to this practice. The facility should inform the resident of this practice, in accordance with §483.10(g)(16), F581, Notice of rights and services.
      • In a SNF, the first physician visit (this includes the initial comprehensive visit) must be conducted within the first 30 days after admission, and then at 30 day intervals up until 90 days after the admission date. After the first 90 days, visits must be conducted at least once every 60 days thereafter.
      • In a NF, the physician visit requirement may be satisfied in accordance with State law by an NPP who is not an employee of the facility but who is working in collaboration with a physician and who is licensed by the State and performing within the state’s scope of practice. (See §483.30(f)).
      • In SNFs and NFs, facility policy that allows NPPs to conduct required visits, and/or allows a 10-day slippage in the time of the required visit, does not relieve the physician of the obligation to visit a resident personally when the resident’s medical condition makes that visit necessary.

 

For further guidance, contact your local state surveyor’s office. The Code of Federal Regulations can be found here.

 

Stacy Baker, OTR/L, CHC, RAC-CT
Director of Audit Services

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