You would be hard-pressed to find an adult day care provider in a state where licensure is required who does not know the rules that apply to their business model. This is commendable and often impressive. Regulatory compliance can save lots of grief.
Many programs are adding clinical components, which widens to what extent their programs can serve the community in effective ways. Some are now CMS certified or contemplate becoming certified as Comprehensive Outpatient Rehabilitative Facilities, (CORF). If you read the financial guidelines published by the Centers for Medicare and Medicaid Services, (CMS) you will find that no order is required to initiate rehabilitative services. You would be informed that the payments made to you are based upon the Treatment Plan, approved by a physician. A licensed nurse practitioner can prepare and authorize the Treatment Plan under the supervision of your CORF’s attending physician. (Click Here for a further explanation)
That being said, it is not recommended that you execute services without the physician order and generally state contracted surveyors auditing for Medicare will want to see that order. CMS is not going to provide you with a form, however, you can likely locate one to satisfy this purpose and make the signed order a part of the patient’s medical record.
One thing for sure is that in the absence of it, programs can be subjected to fraud accusations and billions in services can be performed without a physician or approved equivalent professional discipline deciding that the services are clinically appropriate and necessary. Further, even though the CMS guidelines speak one way, a state government often has policies affecting how certain licensed professionals must approach delivering their services. This may include the need for an official order indicating physician approval.
Let’s operate within the established framework and in the process promote true benefits for those we are called upon to serve in adult day programs. In the end we will continue to make a real difference across America.
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