Healthy Kansans living in safe and sustainable environments

Greg Reser, Director, Health Facilities Program Bureau of Child Care and Health Facilities

Topics To Be Discussed Who we are and what we do SFY 2011 survey results FFY 2012 expected survey activity New requirements related to telemedicine in CAHs Visitation Rights

HEALTH FACILITIES PROGRAM RESPONSIBILITIES Licensed Providers General Hospitals Special Hospitals Critical Access Hospitals Ambulatory Surgical Centers Home Health Agencies Medicare Certification Hospitals CAHs ASCs Home Health Agencies Hospice ESRD Rural Health Clinics Outpatient PT CORFs PPS Units

CAH SURVEYS FFY 2011 (Through ) Resurveys – 20 Revisits – 6 Complaint investigations – 9 EMTALA – 1 Total - 36

CoPs Out of Compliance 5 Facilities – Physical Environment (220) Provision of Service (270) Clinical Records (300) Surgical Services (320) Periodic Evaluation and Quality Assurance Review (330)

Telemedicine Services in Hospitals and CAHS On May 5, 2011, CMS published final rule (76FR2550), effective July 5, 2011, governing agreements under which a hospital or CAH may provide telemedicine services to its patients. “Telemedicine as the term is used, means the provision of clinical services to patients by physicians and practitioners from a distance via electronic communications.

Telemedicine Services (con’t.) Telemedicine Services must be provided under a written agreement between the CAH and one or more: Distant-site hospitals that participate in Medicare; or Distant-site telemedicine entities (provides telemedicine services, is not a Medicare participating hospital, and provides services in a manner that enables the CAH to meet COPs)

Telemedicine Services (con’t.) Must be a written agreement that ensures distant-site hospital or telemedicine entity has granted privileges to the individual telemedicine physicians and practitioners providing those services to CAH patients and that they hold an appropriate license. The distant-site hospital or entity must provide a list of those privileged there and their current privileges to the CAH.

Telemedicine Services (con’t.) If agreement is with a distant site telemedicine entity, it must state the entity is a contractor of the CAH furnishing contracted telemedicine services in a manner that permits the CAH to comply with all applicable COPs. The CAH must review the services provided to its patients by physicians and practitioners under the agreement and provide feedback addressing, at least, complaints and adverse events to entity.

Telemedicine Services (con’t.) SURVEY PROCEDURES: Ask the CAH leadership if it uses telemedicine services. Yes? Ask to see the written agreement Does CAH have documentation it granted privileges to each telemed physician/practitioner? Did CAH governing body or responsible individual make the privileging decisions based on the documentation? Is there a list provided by the distant-site entity of the telemedicine physicians/practitioners covered by the agreement, including privileges and licensure info.?

Telemedicine Services (con’t.) SURVEY PROCEDURES: Is there evidence the CAH reviews the services provided, including any adverse events and complaints and provides written feedback to the distant-site telemedicine entity? Ask the CAH how it verifies that the entity fulfills the agreement in terms of privileging process and assuring that services are provided in a manner to all CAH to meet all applicable CAH requirements.

Telemedicine Services (con’t.) WHERE DO I FIND MORE INFORMATION? S and C Letter July 15, detail.asp?filterType=dual,%20keyword&filterValue=11- 32&filterByDID=0&sortByDID=4&sortOrder=ascending&ite mID=CMS &intNumPerPage=10 Interpretive Guidelines Appendix W AH.pdf

Regulation Amendment Federal Register / Vol. 75, No. 223 / Friday, November 19, 2010 / Rules and Regulations Condition of Participation: Provision of Services New (f) Patient Visitation Rights HANDOUT

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