CMS SOM App. W, Tag C-0998

physician assistant, or clinical nurse specialist, a doctor of medicine or osteopathy

on the staff of the CAH is notified of the admission.

Interpretive Guidelines §485.631(c)(3)

The CAH regulations do permit licensed mid-level practitioners, as allowed by the State,

to admit patients to a CAH. However, CMS regulations do require that Medicare and

Medicaid patients be under the care of an MD/DO if admitted by a mid-level practitioner

and the patient has any medical or psychiatric problem that is present on admission or

develops during hospitalization that is outside the scope of practice of the admitting

practitioner. Evidence of being under the care of an MD/DO must be in the patient’s

medical record. If a CAH allows a mid-level practitioner to admit and care for patients, as

allowed by State law, the governing body (or responsible individual) and medical staff

would have to establish policies and bylaws to ensure patient safety. As applicable, the

patient’s medical record must demonstrate MD/DO responsibility/care.

Survey Procedures §485.631(c)(3)

• Verify that admitting privileges are limited to those categories of practitioners as

allowed by State law.

• Verify that patients are admitted only by those practitioners who are currently

licensed and have been granted admitting privileges by the governing body (or

responsible individual) in accordance with State laws and medical staff bylaws.

• Verify that an MD/DO is responsible for and is monitoring the care of each

Medicare or Medicaid patient for all medical problems during the hospitalization.

• If mid-level practitioners admit patients, verify that every Medicare/Medicaid

patient is being monitored by an MD/DO who is responsible for any medical

problem outside the scope of practice of the admitting practitioners.