Historically, only physicians, dentists and podiatrists have been authorized under Ohio law to admit patients to a hospital. This sometimes resulted in creative resolutions such as having an advanced practice provider (APP) (e.g., an advanced practice registered nurse or physician assistant) admit a patient “under the name of” an admitting physician.
The problem was solved, effective May 20, 2014, when Ohio Revised Code § 3727.06 became law and specifically permitted clinical nurse specialists, certified nurse-midwives, certified nurse practitioners and physician assistants to admit patients to hospitals if certain conditions are met.1Accordingly, as indicated in a previous bulletin, if a hospital and its medical staff want to extend admitting privileges to an APP, it may now do so provided appropriate changes to the medical staff governing documents and delineation of privileges are made.
But you cannot stop there. As a condition of payment for hospital inpatient services under Medicare Part A, the Medicare regulations require physiciancertification of the medical necessity that such services be provided on an inpatient basis and authentication of the admission order is one element of the required physician certification. [Note: There are other elements of the required physician certification that must also be met for payment but they are outside the scope of this E-Alert.] Furthermore, only medical doctors, doctors of osteopathic medicine, dentists and podiatrists may certify an admission. As such, if an Ohio hospital decides to grant admitting privileges to an APP, CMS will not pay for such an admission unless a physician has, as part of the required certification, authenticated the APP’s admission order.
While there is no specific certification form or certification statement, the authentication requirement for admission orders may be met by the signature or countersignature of the order by the certifying physician. The physician certification must be completed, signed, and documented in the medical record prior to patient discharge.
Finally, please note that CMS has proposed to eliminate the certification requirement for all but outlier stays.