In the final 2009 Inpatient Perspective Payment System rules (IPPS) additional language was added regarding community on-call coverage. This addition permits two or more hospitals to create and implement a plan to coordinate on-call coverage in a specific geographical area. Basically allowing two or more hospitals to divide responsibility for a specialty.
Centers for Medicare and Medicaid Services (CMS) provides examples for how a community call plan might work. For example two hospitals could agree that one hospital would be designated as the on-call facility for interventional cardiac care, while the other hospital is designated as the on-call facility for interventional neurologic care. Another example is that one hospital could be designated as the on-call facility for the first 15 days of the month with the other hospital designated for the remaining days.
There are several reasons to create a community on-call coverage agreement listed below are some of the more obvious;
- If you are in an area with multiple hospitals and too few providers to provide coverage, it may be better to share this responsibility instead of having to occasionally close for the service.
- If you are in an area with multiple hospitals and one hospital has better facilities for a certain services such as Interventional Neurology, this may provide for better patient outcomes.
- You have several hospitals within a geographical area that are owned by the same system and need to reduce costs by consolidating services while maintaining your Trauma Level Designation.
While you should consult with your hospital attorney or contact a firm that specializes in this type of work, listed below is a list of minimum requirements that CMS sets forth when considering and developing a community on-call coverage agreement.
- A clear understanding of each participating hospital’s on-call coverage responsibility, including when each hospital is responsible for on-call coverage, and what services it will provide. Basically everyone must clearly understand their responsibility and it must be in writing in a defined policy.
- Definition of the specific geographic area which the community on-call coverage agreement applies.
- Each hospital that agrees to participate must sign an agreement legally binding them to the terms and conditions of the coverage agreement.
- Local and regional EMS must be aware of the agreement and have formal protocols in place to comply with the community on-call coverage arrangement.
- In the agreement, each hospital must acknowledge its individual obligation to screen at each hospital for an emergency medical condition and administer stabilizing treatment within its capability even if and when the hospital is not designated as the on-call hospital. To maintain EMTALA compliance this must be done before a transfer to the on-call facility can take place.
- This policy agreement must be assessed annually by each participating hospital.
There are a few other general things to be aware of when considering a community on-call agreement.
- Not all hospitals within the geographical area are required to participate.
- The formal plan or agreement that your legal team creates does not need to be approved by CMS.
- There has been some discussion regarding antitrust and/or collusion that you will want and need to consider.
- Be sure to have a good web-based on-call management system that can clearly communicate who is on-call at each facility for each specialty to avoid confusion and delay patient care.
- Be sure to have a good web-based change notification process that integrates with your on-call management system to avoid confusion among the physicians and Emergency Department staff.
Key Takeaway: Although there are many hurdles to overcome in implementing a community on-call coverage agreement, it may be in the best interest of the participating hospitals, specialty physicians and most importantly patients in order to provide the best medical care in your community.
Be sure to consult an Attorney before entering into any formal agreements. The author of this article is not an Attorney and this blog post is not to be considered legal advice.
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