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Second Opinions > Conditions of Participation

Conditions of Participation

Has anyone been surveyed under the new CoP from CMS and has anyone been told by the surveyors verbally that all H&P's must be on the chart one day prior to surgery - meaning they can't be done that morning? Same day patients since in a fracture or urgent type clinic that are done the same day are the only exception.

We understand from another center that the surveyors are being instructed that H&P's must be done at least one day before the scheduled procedure and that doing them the morning of is not in keeping with the promulgated regulations and guidelines as we interpret them. What has been your experiences?

Started by: Stuart Katz (Administrator/Director/Manager/Owner/Exec. Officer) at March 2, 2010 (2:59 pm)

Comments and Responses

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Great hear you were recently surveyed and told by CMS you did not need H & P before patient arrived. Does anyone know if there has been a response yet from CMS on this?

"AGA Investigating CMS History and Physical Requirements for Endoscopy Centers
By Staff | January 29, 2010 Tags: AGA | CMS | history | physicals | surgery centers
Several ambulatory endoscopy suites have been cited for failure to meet new Centers for Medicare & Medicaid Services' requirements for history and physicals prior to procedures, which has prompted the American Gastroenterological Association to investigate the citations, according to an AGA news release.

According to the CMS requirement, which went into effect on Dec. 31, 2009, the medical history and physical should be completed no more than 30 days prior to the procedure and should be available in the patient's record and reviewed by the physician prior to the procedure. The AGA is looking into whether this precludes examinations performed the day of surgery.

The AGA received several communications from members that their centers had been cited for failing to meet the requirement and is currently investigating whether the citations were due to misinterpretation of surveyors or a change in CMS policy."

I have not been successful finding any news and got nowhere contacting CMS.

Lynn Jenkins (Administrator/Director/Manager/Owner/Exec. Officer) at May 11, 2010 (1:27 pm)

We do a considerable volume of patients that are scheduled on very short notice. We are a level 1 Trauma Center and many paitents are here for surgery two or three and there is not much up front notice time. I would love it, if we had all paperwork done a minimum of 1 day out but withourpractice this is not possible. In and ASC you still have similar types of cases, there for diligence needs to be exercised in the amount of rigor you use in your pre op criteria

Chris E. (Director, Surgical Services/Director of Nursing) at May 3, 2010 (2:18 pm)

There is nothing in the "Guidance for Surveyors" Manual that states this has to be done a day in advance. Standard 416.52(a)Admission and Pre-surgical Assessment states "The patient's medical history and physical assessment must be placed in the patient's medical record prior to the surgical procedure." The Interpretive Guideline states, "Ideally the comprehensive H&P must be submitted to the ASC prior to the patient's scheduled surgery date, in order to allow sufficient time for review of the H&P by the ASC's medical staff and adjustments if necessary, including postponement or cancellaation of the surgery. At a minimum, the H&P must be placed in th patient's medical record prior to the pre-surgical assessment required under 416.52(a)."
Our surgeons make a note on their H&P's, after they examine the patient in pre-op just prior to their surgery, that there has been no change in the patient's condition since they were last seen by the surgeon.

Pamelia P. (Administrator/Director/Manager/Owner/Exec. Officer) at April 1, 2010 (10:18 am)

My center has been surveyed under the new guidelines. Our surveyors did not indicate that H&Ps must be in the record at least one day before, and they did state that an H&P done immediately prior to the procedure would be acceptable. They did indicate that the H&P must be "comprehensive" however - and that may be subject (in my opinion) to some interpretive license.

Tara McKinley (Director, Surgical Services/Director of Nursing) at March 4, 2010 (10:34 am)

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