scriptiveAuthority.php. Failure to register prescriptive delegation is an administra- tive violation that can carry a fine of up to $5,000 per incident. Improper supervision of and delega-
tion to PAs or APNs could result in the board requiring offending physicians and NPPs to complete continuing edu- cation, undergo chart monitoring, and possibly pay fines. Ms. Robinson says patient complaints are the prime source of alleged supervision and delegation violations. “If a patient walks into an orthopedic practice and is seen only by a PA who admits never having treated that pa- tient’s type of injury, the physician and PA are likely going to run into a delega- tion violation. If a physician takes a two- month vacation and has no communica- tion with or oversight of an NPP during that time, that physician has a supervi- sion issue,” Ms. Robinson said. Because the legal requirements for
working with NPPs are complex and de- tailed, Ms. Robinson suggests physicians have an attorney review their protocols to ensure they’re meeting TMB rules and adhering to state law. Mr. Rivera says physicians often face challenges pertaining to supervision, scope of practice, contracts, and com- pliance when using NPPs. He says it’s a good idea for physicians to have proto- cols in place that describe NPPs’ scope of practice and articulate their practice parameters. “For example, in an orthopedic prac-
tice setting, it’s helpful for a physician to have protocols that outline NPP treat- ment of chronic versus acute pain. That way, the NPP has appropriate guidance about how care should be provided and explicit instructions from the physician regarding the NPP’s scope,” Mr. Rivera said. To avoid disputes, Mr. Rivera says physicians should execute clear employ- ment contracts with the NPPs and cre- ate a well-defined compliance plan to confirm an NPP’s scope of practice is ap- propriate and meets quality of care mea- sures. Strong, effective compliance plans incorporate legal requirements, practice policies, risk management efforts, qual- ity control measures, and data gathering,
A Special Referral for Special Needs.
Many patients with health conditions/risks need medical-related services outside your scope of care. A referral to Medicaid case management services could make all the difference for them. Case managers help patients access specialty referrals, medical equipment, and other needs. And let you focus on what you do best.
To make a referral, call 1-877-THSTEPS or download a referral form at
www.dshs.state.tx.us/caseman
Taking New Steps March 2012 TEXAS MEDICINE 31
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