Podiatrists Completing H&Ps

QUESTION:

Can a podiatrist complete an H&P per CMS regulations?

ANSWER:

Yes.  CMS 482.22(c)(5) addresses who may complete a history and physical.  The regulations states that the medical staff bylaws must include a requirement that:

• A medical history and physical examination be completed and documented for each patient no more than 30 days before or 24 hours after admission or registration, but prior to surgery or a procedure requiring anesthesia services.
• The medical history and physical examination must be completed and documented by a physician (as defined in section 1861(r) of the Social Security Act), an oromaxillofacial surgeon, or other qualified licensed individual in accordance with State law and hospital policy.
  • Section 1861(r) defines a physician as a:
    • Doctor of medicine or osteopathy
    • Doctor of dental surgery or of dental medicine
    • Doctor of podiatric medicine
    • Doctor of optometry; or
    • Chiropractor
  • In all cases the practitioners included in the definition of a physician must be legally authorized to practice within the State where the hospital is located and providing services within their authorized scope of practice.
  • In addition, in certain instances the Social Security Act attaches further limitations as to the type of hospital services for which a practitioner is considered to be a “physician.” For example, a chiropractor is considered a physician only with respect to treatment by means of manual manipulation of the spine (to correct a subluxation). Other qualified licensed individuals are those licensed practitioners who are authorized in accordance with their State scope of practice laws or regulations to perform an H&P and who are also formally authorized by the hospital to conduct an H&P. Other qualified licensed practitioners could include nurse practitioners and physician assistants.
  • More than one qualified practitioner can participate in performing, documenting, and authenticating an H&P for a single patient. When performance, documentation, and authentication are split among qualified practitioners, the practitioner who authenticates the H&P will be held responsible for its contents. (71 FR 68675)

 

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