This week’s Ftag of the Week on the CMSCG Blog is F713 Physician for Emergency Care, Available 24 Hours, which is part of the Physician Services regulatory group. As the name of the Ftag suggests, this regulation requires that nursing facilities provide or arrange for physician services 24 hours a day/ 7 days a week in case there is an emergency.
Surveyors are guided to see if a facility has an on-call physician for medical emergencies, but also – does the physician respond? This is where the many issues cited on survey are identified. Facilities have been cited at an Immediate Jeopardy or Actual Harm level for instances where staff attempted to contact the on-call physician and did not receive a timely response, resulting in a delay in timely treatment or transfer of the resident to the emergency room for care. The Interpretive Guidance (IG) notes that facilities are responsible for having a physician available 24/7 for emergencies that do not require medical care in an alternative setting, but ensuring that a resident is transported to a medical facility does not relieve the facility of its responsibility to have a physician available.
Surveyors are also asked to review whether residents are unnecessarily sent to the hospital, and if their needs could have been met in the facility if a physician had been available during the emergency situation. Facilities have been cited under F713 for failure to have a physician respond to critical/abnormal lab results and/or radiology findings, not being able to have a physician clarify issued orders needed for the provision of emergency care, or even when physician’s orders state that the practitioner should be alerted when a resident had elevated blood sugar and the physician does not respond.
In many of these cited situations, the on-call physician was on vacation, out of the country, or in a similar situation that prevented timely response, but coverage had not been arranged prior to the physician’s availability status changing. In other cases, staff made multiple attempts to reach the physician, received no response and ended up contacting the Director of Nursing to get permission to transfer the resident to the hospital. Unfortunately, this is more common than we would like to think and a delay in response from the physician with the Director of Nursing having to make a transfer decision has a high potential for a negative outcome for the resident. It is important that staff make attempts to reach the physician and document these attempts, but staff need to ensure that they do not unduly delay contacting decision-makers so as to not delay treatment for emergency situations. Facilities should have a written protocol in place that staff can follow in these situations, but it is also essential to ensure that there is a process in place to identify when a physician may need coverage and how it will be obtained. The Medical Director should be actively involved in monitoring the medical staff’s response to emergency situation and implementing necessary changes in medical staff schedules and coverage arrangements. In the case of one physician, there was a death in the family that required travel outside of the country on short notice – how would you address this situation if it happened in your building?