April 17, 2013
ALTSA: NH #2013-006
S&C 13-15: PHYSICIAN DELEGATION OF TASKS IN
SKILLED NURSING FACILITIES (SNF) & NURSING FACILITIES (NF)
Dear Nursing Facility/Home Administrator:
The Centers for Medicare & Medicaid Services (CMS) has issued a survey and certification (S&C) letter clarifying the regulatory differences concerning physician delegation of tasks to non-physician practitioners (NPPs including nurse practitioners, physician assistants, clinical nurse specialists) in SNFs and NFs. The distinction in policies between these two settings (SNFs & NFs) is based in federal statute and regulation.
Highlights of the S&C letter:
- Matrix identifying responsibilities for NPPs working at SFF vs. NF on page 4.
- Implementation of section 3108 of the Affordable Care Act, which added physician assistants to the list of practitioners that can perform Skilled Nursing Facility (SNF) level of care certifications and re-certifications.
- Clarification of policy on co-signing orders in SNFs & NFs.
To read the details of the memorandum online, please visit:
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-15-.pdf
Please also note that the Quality Indicator Survey process has not changed.
Contact your local RCS Field Manager if you have any questions.
Sincerely,
Joyce Pashley Stockwell, Director
Residential Care Services