An effective emergency transfer depends on the existence of an established procedure, which is why it is highly recommended to create a written agreement between the CSA and its designated local hospital, even if it is not required by state accreditation rules or bodies. Many of the transfer agreements I audited did not address these three elements. Sketch returns may result in citations for violating the terms of participation in the CMS, but EMTALA is unlikely to apply to a back-transfer situation in most cases. 1. CSA must not have a written transfer contract or hospital planning privileges for all physicians. Centres must provide hospitals with a document containing information about their surgery and patient population. 2. CMS is working on a final proposal to require the ACS to develop a policy to identify patients who require a medical history and physical examination prior to the operation, instead of asking all patients 30 days before the procedure. ASCA describes here the possible information CMS would need about the patient`s history and physical examination. Currently, operating centres must have a written transfer contract with a hospital to transfer a patient or ensure that all doctors who perform an operation have privileges at a nearby hospital.
The active conditions of a hospital visit vary from case to case and must be defined in the written document. A transfer agreement may have an expiry date or it may indicate that it will remain in effect until a party terminates the contract. However, current issues focus on the topic of transfer. With respect to this issue, CMS has indicated in several of my cases that “removal” is an authorized provision in a transfer contract as long as three criteria are included: Final rule: CMS is in the process of finalizing the proposal to revise the requirement set out in section 416.47 b) (2) in order to “provide a significant medical history and physical examination results if necessary.” They are in the process of finalizing the proposal to remove the requirement of Section 416.52 A) that each patient should not have to undergo a medical examination more than 30 days prior to the scheduled operation and replace it with the requirement for CSAs to develop and maintain a policy identifying patients who require a medical examination and physical examination prior to the operation. The institution`s policy must provide the timetable for the completion of the H-P before the operation. The directive should also address the following factors, but should not be limited to the age of the patient, the diagnosis, type and number of procedures planned for the same surgical date, comorbidities and the level of anesthesia expected. At admission, each patient must have a pre-surgical assessment performed by a physician or other qualified physician, in accordance with the national health and safety laws that perform the operation. While 43 states require CET accreditation, only 30 require the ability to obtain emergency outpatient care. Fifteen of them are asking for a hospital transfer contract.
The others require either an agreement or a hospital that grants privileges to CSA surgeons. (See the “State Situations” sidebar.) “This rule allows outpatient surgical centres to remain effective and affordable outpatient surgery providers without compromising their commitment to patient safety,” said William Prentice, CEO of ASCA.