CMS Clarifies Delegation of Physician Tasks in SNFs and NFs

S&C Memorandum 13-15-NF replaced a 2003 guidance memo concerning physician delegation of certain tasks in SNFs and NF to non-physician practitioners (NPP) such as nurse practitioners, physician assistants, or clinical nurse specialists.  Due to federal regulation, there is a difference between SNFs and NFs in terms of what a physician can delegate to NPPs.  The first part of the analysis is to determine (1) which setting, SNF or NF, are the physician services being provided, (2) whether the task must be personally performed by the  physician, and (3) whet her the NPP is employed by the facility.  Certain tasks, such as conducting physician visits, writing orders, signing certifications and re-certifications should be analyzed to ensure proper personal action by the physician or proper delegation to an NPP.

The S&C Memorandum discusses the distinctions between SNFs and NFs for physician required visits and proper delegation to NPPs and provides a helpful chart to depict the various elements at play.  To read the memo, see https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-15-.pdf.