PA and NP Policies Can Help Maximize Financial Gains
Consider Items Under General Compliance and Clinical Policy

By Bianca Belcher, MPH, PA-C

PA and Nurse Practitioner (NP) policies are important for organizations and institutions to consider on two strategic fronts: maximizing financial gain and minimizing risk.

PA and NP policies can help maximize financial gains by minimizing redundant work, eliminating artificial barriers of practice, and determining allocation of work for productivity and outcome tracking. For example, if hospital X required all PA and NP medical notes to be cosigned by a physician as per hospital policy but physician cosignatures were not required by state or federal law we consider, this an artificial barrier that forces work to be duplicated for the sole purpose of meeting a policy requirement and not for better patient outcomes.

Under risk mitigation there are two sub-categories to consider when looking at policy: general compliance and clinical compliance policies.

Items to consider under general compliance:
• Anti-kickback and stark liability
• Emergency Medical Treatment and Labor Act (EMTALA)- PA and NP and facility policies
• Medical documentation
• Appropriately listing for PAs and NPs: Medicare cost A reporting versus part B enrollment

Items to consider under clinical policy:
• Informed consent
• Surgical site marking
• Institution policies regarding PA and NPs as first assists
• Competency assessments such as FPPE/OPPE

For example, when considering writing or amending policy around informed consent and/or surgical site marking by PAs and NPs, there are multiple regulatory requirements governing different facilities that must be considered. The requirements include, but are not limited to, 1) state law, and, 2) Medicare conditions of participation (CoPs), 3) accreditation standards from industry regulations such as the Joint Commission, Healthcare Facilities Accreditation Program, etc.

More Resources

Organizational PA and NP Policy Considerations
The booklet may be used on its own or in conjunction with the accompanying CHLM Symposium 2017 session titled “Hospital Regulatory Bootcamp and Beyond” which can be accessed through Leadership on Demand for free.

Compliance Assessment
This ten-question quiz on legal and regulatory issues relating to PA and NP utilization can help an organization better understand its compliance position.

Bianca Belcher, MPH, PA-C, is Director, Center for Healthcare Leadership & Management (CHLM). Contact her at [email protected]