Sckc rural health clinic policies 5 10 16 1 by South Central Kansas Medical Center

South Central Kansas Rural Health Clinic

South Central Kansas Rural Health Clinic 515 N Summit Street Arkansas City, KS 67005 PH. (620) 442-4850 FAX (620) 442-9560

RURAL HEALTH CLINIC POLICIES

Reviewed and Approved By: ___________________________________ ________________ Dr. Kamran Shahzada, MD Date ___________________________________ ________________ Angela Ziegler, NP-C Date ___________________________________ ________________ Virgil Watson, CEO Date

South Central Kansas Rural Health Clinic

Table of Contents Policy Number Policy Name

Page

001

Staff Organization and Responsibilities .......................................... 6 Ownership ....................................................................................... 6 Staffing ............................................................................................ 6 Medical Supervision ........................................................................ 7 Guidelines for Utilization of Physician Assistant ............................ 7 Nurse Practitioner Addendum A: Hours of Operation Physician Credentialing Organizational Chart

002

Fire and Disaster ........................................................................... 11 Addendum B: Schematic of Building

003

Nurse Practitioner Job Description ............................................... 12

004

Preventive Maintenance and Safety of Bio-Medical Equipment ..................................................................................... 15 General Information ..................................................................... 16 Safe Use of Clinic Equipment ........................................................ 16 Electrically Energized Equipment.................................................. 16 Patient Transport Equipment ....................................................... 17 General Medical Therapy Equipment ........................................... 18 Equipment Maintenance .............................................................. 18 Lifting and Transfer of Patients ..................................................... 19 Fire Plan ........................................................................................ 19 Smoking Policy .............................................................................. 19 New Personnel .............................................................................. 19 Personnel Training ........................................................................ 19 Enforcement ................................................................................. 19 Addendum C:

005

Drugs and Biologicals .................................................................... 20 Storage .......................................................................................... 20 2

South Central Kansas Rural Health Clinic Disposal ......................................................................................... 20 Prescriptions ................................................................................. 20 Records ......................................................................................... 20 006

Medical Records............................................................................ 21 Authorization for Disclosure..................................................... 22 Policy Number Policy Name

Page

Authorization for Release of Records-Requirements .............. 22 Policy for Disclosure to Patients ............................................... 24 Policy for Internal Disclosure .................................................... 25 Administration ........................................................................... 25 Patient Care ............................................................................... 25 Peer Review/Patient Care Evaluation ....................................... 25 Education and Research ............................................................ 26 Legal Counsel ............................................................................. 26 Institutional Affairs .................................................................... 26 Policy on External Disclosure to Third Party Contractors And Insurance Carriers .............................................................. 26 Third Party Contractors ............................................................. 26 Other Insurance Carriers and third Party Payers ...................... 26 Champus (Civilian Health and Medical Program of Uniformed Services) ............................................... 27 Policy on External Disclosure to Other Health Care Institutions ................................................................................ 28 Policy on External Disclosure to Other Physicians (Individual & Group Practices) ................................................... 29 Policy on External Disclosures (Attorneys) ................................ 29 Policy on External Disclosure (Governmental Agencies) ........... 29 Policy on External Disclosure (Medical Examiner/ Coroner) ..................................................................................... 29 Policy on External Disclosure (Evidence and Investigation).............................................................................. 30 Policy in Response to Subpoenas and Court Orders .................. 30 Policy on External Disclosure (Fees for photocopies) ................ 34 Policy for Requests for Correction or Amendment 3

South Central Kansas Rural Health Clinic To the Medical Record ............................................................... 35 007

Patient Care Policy ........................................................................ 36 Rural Health Clinic Services ...................................................... 36 Rural Health Laboratory Services ............................................. 37 Primary Culturing for Transmittal ........................................ 37 Specimen collection ........................................................ 37 Transportation ................................................................. 38 Hand/Mouth Contract ..................................................... 39 Handwashing ................................................................... 39 Work Surfaces ................................................................. 39 Specimen Labeling ........................................................... 39 Sample disposal............................................................................ 39 Clothing ........................................................................... 40 Shoe Requirements ......................................................... 40 Cosmetics ........................................................................ 40 Beverages ........................................................................ 40 Medical Management of Health Care Problems .......................... 40 Medical Emergency ........................................................ 41 Equipment ...................................................................... 41 Training ........................................................................... 41 Working Arrangement .............................................................. 42 Condition of Understanding .......................................... 42 Patient Referral ......................................................... 42 Medical Records ........................................................ 42 Addendum D: Laboratory Policies and Logs

008

Patient Notice ............................................................................... 43

009

Non-Discrimination Policy......................................................... need

010

Job Descriptions ............................................................................ 45

011

Annual Evaluation ......................................................................... 53

012

Bad Debt Policy ............................................................................. 53 General Information ................................................................. 54 Definitions ................................................................................ 54 Criteria for Allowable Bad Debt................................................ 54 4

South Central Kansas Rural Health Clinic Charging of Bad Debts and Bad Debt Recoveries..................... 55 013

CMS Fraud, Waste and Abuse....................................................... 55

014

Minor Surgery Policy ..................................................................... 59 DO YOU NEED THIS POLICY

South Central Kansas Rural Health Clinic

Staff Organization and Responsibilities 1.

RHC #001

It is the policy of South Central Kansas Rural Health Clinic that the following lines of authority and responsibilities will be established. A.

Ownership The Owner of the clinic is South Central Kansas Medical Center doing business as South Central Kansas Rural Health Clinic in Arkansas City, Kansas and is responsible for the operation of the clinic.

Authorization Dr. Kamran Shahzada, Medical Director Kris Frahm, Acting Office Manager Virgil Watson, CEO

Staffing The Clinic has a Health Care Staff which includes one or more physicians, and one or more physician assistants/nurse practitioners. The staff also includes the necessary ancillary personnel who are supervised by the professional staff. The staff is sufficient at all times to prove the services essential to the operation of the clinic.

Three categories are to provide structure and organization of the Medial Staff of the South Central Kansas Rural Health Clinic: Qualification of membership for Professional Employees: 1. Credentialed by South Central Kansas Medical Center 2. Approval at Medical Executive Committee 3. Approval at South Central Kansas Medical Center Board of Trustees Categories: 1. Active Staff: is employed by South Central Kansas Medical Center and documentation is located behind the tab for Professional Licensure in Addendum A.

South Central Kansas Rural Health Clinic 2. Applications Forms: Application forms â&#x20AC;&#x201C; a copy of the hospital application will be kept on file at the Clinic. The Clinic Manager and Medical Staff will have access to and review all applications.

Medical Staff Clinic: 1. Medical Director:

Kamran Shahzada, MD.

2. Additional:

Rhonda Green, MD Eric Thomson, MD Angela Ziegler, NP-C

Meetings: The Medical Staff shall meet as often as necessary, but at least quarterly. Meetings are generally to be held the 3rdWednesday of the month designated. Those in attendance should be: 1. Medical Staff Members (active) 2. Clinic Manager 3. Virgil Watson, CEO Medical Supervision Dr. Kamran Shahzada, MD is the Medical Director and is responsible for the overall direction of the facility. The Office Manager is responsible for the business functions and the overall function of the clinic operation, including scheduling and supervising billing and clerical personnel. The Mid-level practitioner position reports to the Medical Director for Medical/operational issues and to the Office Manager for business office matters. The Organization chart is presented under the Organizational Chart Tab

2. GUIDELINES FOR UTILIZATION OF PHYSICIAN ASSISTANT/NURSE PRACTITIONER I.

Purpose: To define and clarify guidelines and procedures for utilization of Nurse Practitioner at South Central Kansas Rural Health Clinic.

II.

Policy: Utilization of Nurse Practitioner at South Central Kansas Rural Health Clinic will be consistent with Kansas State Board of Healing Arts and the general guidelines an policies established by the Bylaws of South Central Kansas Medical Center. 7

South Central Kansas Rural Health Clinic III.

General Considerations A. Nurse Practitioner:Currently registered by the Kansas State Board of Nursing for Nurse Practitioner, maintained by the Kansas Board of Healing Arts. Documentation is located behind the tab for Professional Licensure.

B. Each Nurse Practitioner will have a specifically designated Responsible Physician. However, the A.P.R.N. may perform duties under the direction of more than one physician. Alternate physicians must be named to function during the absence of the physician with primary responsibilities. The â&#x20AC;&#x153;Responsible Physicianâ&#x20AC;? will be present for sufficient periods of time, at least once in every 2 week period and is available through direct telecommunications for consultation, assistance with medical emergencies, or patient referral. C. As directed by the staff Bylaws and Medical Ethics, any physician who will be unavailable must designate another physician of similar skills to be responsible for his patients. D. Each Nurse Practitioner should be considered individually and be assigned only those duties that are commensurate with his/her qualifications, training, experience, and the extent to which the Responsible Physician provides direction and supervision. IV.

Levels of Assignment A. Duties which may be performed by the Nurse Practitioner as part of his/her routine work assignment include: At least 50% of histories, physical examinations, and other chart entries must be reviewed and countersigned by the Responsible Physician or Supervising Physician. Orders by the A.P.R.N. below will be carried out when written, given verbally or called in, unless in the opinion of the person responsible for carrying out the order, believes the order would not be in the best interest of the patient, in which case, such clinic personnel shall consult with the attending physician or his designated alternate, or in their absence, the President of the Medical Staff. In any case, the order must be reviewed and countersigned by the Responsible Physician or Supervising Physician as soon as feasible, but normally within 24 hours. 1. Performing and transcribing or dictating histories and physicals on new patients. 2. Ordering appropriate laboratory tests, x-rays, EKG and comparable procedures, according to criteria established by the Responsible Physician, copy on file, per application and approved by Medical Staff. 8

South Central Kansas Rural Health Clinic

3. Ordering routine medications and therapeutic procedures (IPPB, etc.) according to criteria established by the Responsible Physician. 4. Dressing changes, wound care, suture removal, routine casting and suturing of lacerations, as directed by the Responsible Physician. 5. Initiating consultations, referrals, and monitoring special procedures, as directed by the Responsible Physician. 6. Drawing blood specimens for testing, starting IVâ&#x20AC;&#x2122;s, and performing other comparable procedures when personnel who customarily perform such procedures are not available. 7. Reviewing laboratory and x-ray results. B. Procedures which may be performed by the Nurse Practitioner in emergency situation pending the availability of a physician: Managing any situation which imposes immediate threat to life or limb, i.e.: 1. Cardiac arrest 2. Acute respiratory failure 3. Hemorrhage I.

Delineation of Responsibilities A. The Medical Staff shall be responsible for the following: 1. The adoption of guidelines for the Nurse Practitioner, which will be consistent with the general guidelines and policies established by the Staff Bylaws.

2. Establishing procedures for handling review of qualification, appointment privileges, reappointment, discipline, termination, or curtailment of privileges as directed by the Staff Bylaws. 3. Maintaining a current roster of the Nurse Practitioner which specifically names the Responsible Physician and his/her designated alternatives. 4. Periodical review of all policies affecting the Nurse Practitioner. B. The Responsible Physician: 9

South Central Kansas Rural Health Clinic

1. Any physician who is a member of the Active Medical Staff may designate a Nurse Practitioner to perform for and on behalf of him/her, to the extent permitted by these guidelines, those acts, as agent of the Responsible Physician/Nurse Practitioner, such acts to be considered the acts of the physician, for which the physician shall be directly responsible. 2. The Responsible Physician shall assume all responsibility for the medical care of his/her patient(s). 3. The Responsible Physician shall be responsible for all orders or medical records for his/her patient whether personally written or written by the Nurse Practitioner. 4. The Responsible Physician shall review 10 charts each month per the Kansas Nurse Practice Act. ( see following document) 5. The Responsible Physician shall ensure that the Nurse Practitioner maintains high professionalstandards; both by continuous personal supervision and review of his/her work with ongoing instructions as well as more formalized continuing medical education courses and programs. 6. The Responsible Physician shall ensure that the Nurse Practitioner maintains professional liability insurance. C. The Nurse Practitioner: 1. The Nurse Practitioner shall file with the Clinic Manager a written application form which shall set forth in detail the professional qualifications of the applicant, his/her past practical and hospital affiliation, and his/her personal and professional references. 2. He/she shall designate a Responsible Physician and alternate Responsible Physicians. 3. The Nurse Practitioner shall recognize and be aware of the limitations upon his/her activities with the Clinic as stated in the applicable Bylaws, Rules and Regulations and Medical Staff and directed by these guidelines. He/she is responsible for being aware of any and all federal, state, local and hospital/clinic regulations. 10

South Central Kansas Rural Health Clinic 4. The Nurse Practitioner must sign all histories, physical, chart entries and orders with his/her name (or initials), followed by the initials A.P.R.N.. 5. The Nurse Practitioner shall inform each patient that he/she is a A.P.R.N..and not a physician.

APPROVED: _____________________________________DATE:________________ Kamran Shahzada, MD Medical Director APPROVED:_____________________________________DATE:________________ Angela Ziegler, NP-C

South Central Kansas Rural Health Clinic

Fire and Disaster A.

Policy: 1.

All staff members will receive training in how to respond to emergencies.

Drills 1.

In case of fire or disaster, the staff will help everyone in the building to leave safely using the published escape plan.

Training 1.

It is the policy of South Central Kansas Rural Health Clinic to have an effective plan for evacuation of the building in case of fire or disaster. Documentation for the Evacuation plans for both Fire and Tornado is under the Emergency Evacuations Tab.

Evacuation: 1.

RHC #002

Unannounced fire and disaster drills will be held twice a year. Results will be recorded and kept in the RHC book.

Evacuation Drills 1.

Each employee will familiarize himself/herself with the evacuation plan, as well as the location of normal and emergency exits, fire extinguishers and other pertinent information. An evacuation drill will be held and personnel will be instructed how to deal effectively with emergencies at least twice each year.

South Central Kansas Rural Health Clinic

Midlevel Practitioner Job Description

RHC #003

Title: Nurse Practitioner Reports to:

Collaborative Physicians of South Central Kansas Rural Health Clinic

Job Description: The Nurse Practitioner’s principal responsibility is to provide medical care and treatment to the patients of South Central Kansas Rural Health Clinic. The principal responsibilities and duties are listed below and treatment authorizations are noted in the next section “Nurse Practitioner Privileges”. 1.

The Nurse Practitioner: a. Obtain medical history and perform physicals during Clinic hours. b. Assist in any emergency surgeries or scheduled surgeries only in the Clinic. c. Give assistance to the nursing staff, lab personnel, or EMT’s when the need arises. d. Examine and report on any visitors, patients, or employees who were subject to an accident/incident report. e. See patients in the Clinic. f. Attend Medical Staff meetings, as appropriate. g. Shall maintain current registration and licensure requirements with the Kansas Board of Healing Arts, the Drug Enforcement Agency, and other applicable regulatory agencies. h. Participate in regular marketing and promotional efforts in order to build the practice and to nurture relationships with existing and potential patients.

Collaborative Physician Relationship 1. Nurse Practitioner will report to and participate on call with supervising physicians as determined by the South Central Kansas Board of Directors. 13

South Central Kansas Rural Health Clinic 2. Nurse Practitioner shall be responsible for ensuring that her/his supervising/collaborative physician will see SCKRHC patients regularly seen by the A.P.R.N. as determined by the supervising/collaborative physician. Education and Experience 1. A college graduate of an approved Nurse Practitioner program. 2. Registered with the Kansas Board of Nursing and the Drug Enforcement Agency.

APPROVED: ______________________________DATE: ____________________ Angela Ziegler, NP-C

APPROVED:

______________________________DATE: ____________________ Kamran Shahzada, MD Medical Director

NURSE PRACTITIONER’S PRIVILEGES  

The Nurse Practitioner may do column (1) when the Supervising Physician is present. The Nurse Practitioner may do column (2) when the Supervising Physician is NOT present.

REQUESTED PROCEDURE Perform and Dictate History Perform and Dictate Physical Draw Blood Specimens Catheterization Perform Arterial Punctures Venous Punctures Determine Visual Fields Perform Blood Pressure Readings Pass Nasogastric Tubes Perform Papanicolaou Smears Perform Skin Biopsies Perform I.D. Superficial abscess

COL 1 X X X X

COL 2 X X X X

X X X X X X X

South Central Kansas Rural Health Clinic Removal of Minor Skin Lesions Assist in Surgery Assist in Recovery Order inhalation Therapy Order IV Therapy Order Medications Order Diet Therapy Order Patient Activities Order X-ray Examinations Order laboratory Procedures Order EKG’s Order EEG’s Order Audiometry Order Ambulance Order Physical Therapy Order Consultation Apply Casts Order isolation Removal of Casts Removal of Foreign Bodies Suture or Repair Laceration Skin or Subcutaneous Tissue Performs Emergency Life Saving Procedures in Emergency Situation (Cardiac or Respiratory Arrest, Massive Hemorrhage, etc.) Admit Patient for Physician Removal of Foreign Body from Eye (superficial and non-adhering) Perform Cryocautery, Chemical Cautery and Electrocautery Evaluate and Treat emergency Patients

X X X X X X X X X X X X X X X X X X X X X X

X X

APPROVED: ______________________________DATE: ____________________ Angela Ziegler, NP-C

APPROVED:

______________________________DATE: ____________________ Kamran Shahzada, MD Medical Director 15

South Central Kansas Rural Health Clinic

Preventive Maintenance and Safety of Bio-Medical Equipment Policy RHC #004 A.

Policy: It is the policy of South Central Kansas Rural Health Clinic to maintain all bio-medical equipment in optimal safe operating condition.

Scope: The following policy covers electrical safety of medical equipment, and safe practices concerning patient transfer. 1. Each piece of bio-medical equipment will be inspected by a Bio-Medical Service. This inspection will insure the equipment is in proper operating condition, is safe to use, and is calibrated properly. 2. If an when a malfunction occurs or is suspected, the proper service will be solicited immediately and the equipment will be put out of use until it has been returned to proper operating condition. 3. Each time an inspection or repair occurs, an entry will be made in a log and service report and signed by the service person to verify the event. 4. Employees shall exercise good judgment and take appropriate precautions in the performance of their work. The Clinic Manager or his/her designee shall see that employees are properly trained how to safely perform tasks and use equipment and shall insure that adequate protective equipment is available for use by employees under supervision; recklessness, laxity or carelessness will not be tolerated. Prompt action shall be taken to repair faculty equipment and correct hazardous conditions in all work areas. This will ensure safety for both patient and employees. IMPORTANT ------- ALL HAZARDOUS AND DANGEROUS PROBLEMS SHOULD BE REPORTED IMMEDIATELY TO THE CLINIC MANAGER.

Definitions: A. Electrically energized equipment â&#x20AC;&#x201C; Equipment used by the Clinic that is energized by electrical energy supplied from wall receptacles located throughout the department. 16

South Central Kansas Rural Health Clinic B. Patient transport equipment – equipment utilized by the clinic to transport, move or lift patient from one location to another. Such devices include wheelchairs, stretchers and other related devices. C.

General medical equipment – Equipment utilized by the Clinic for medical purposes that does not require electrical energy for operation. This includes equipment of all types.

General Information: Applicable code information – The regulations presented in this document are based on requirements listed by the National Fire Protection Association Standard 75 bt (Tentative Standard for the Safe Use of Electricity in Patient Care Facilities) and manufacturer’s recommendations.

Safe use of Clinic Equipment The procedures listed will be followed by all personnel utilizing the Clinic Equipment. This information constitutes a check list to be followed prior to use of any equipment item.

Electrically energized equipment: 1. General – All Clinic personnel utilizing any piece of electrically energized equipment will be thoroughly familiar with the device and the physiological effects of the apparatus. The operation manual is available in the department for reference. 2. Equipment concerned – All equipment that requires the utilization of electrical current for its function. 3. Operator safety procedures (prior to use) – The operator of any “electronically energized equipment” comply with the following prior to operation of equipment. a. Know correct operation and application of equipment. b. Visually inspect equipment prior to use for damage to power cord, equipment dials and meters, plug and treatment accessories. c. Any equipment failing visual inspection will be considered unsafe for use and should be tagged “unsafe”, “do not use” before setting it aside. 17

South Central Kansas Rural Health Clinic d. Report unsafe equipment to the Director of the Clinic. 4. Operation (during use) – The operator of any device will be assured of the information listed below during the operation of the equipment. a. Know the physiological effects and treatment information. b. Listen for unusual noises and vibrations while operating equipment. (Report unusual conditions to the Clinic Manager. c. Observe patient reaction. d. Be alert for unusual meter or dial readings. Discontinue use immediately when observing unusual readings. Verify switch position, pad placement, etc., to insure proper operation before continuing. Persistent unusual readings will indicate an unsafe condition. Discontinue use immediately, tag unit “unsafe, do not use”, and report the failure to the Clinic Manager.

Patient Transport Equipment: 1. Equipment Concerned – The following equipment will be checked prior to use: a. Wheelchairs 2. Operator safety checks – Any employee using a piece of patient transport equipment will mentally observe the following procedures: a. Know the proper operation and use of equipment. b. Visually inspect prior to use for damaged mechanical components; missing screws, bolts, or linkages and bent or misaligned components. c. Report problems with the equipment to the Clinic Manager.

General Medical Therapy Equipment: 1.

General – Equipment in this category is used in the treatment of patients. All personnel will be knowledgeable in the proper use of such devices. a. Know the proper orientation and use of the equipment. 18

South Central Kansas Rural Health Clinic b. Visually inspect prior to use for damaged components; missing screw, bolts, etc., and bent or misaligned components. c. Observe operational characteristics and be aware of unusual motion and noises. d. Report problems with equipment to the Clinic Manager. I.

Equipment Maintenance 1. Categories – Equipment maintenance is divided into three areas. a. Operation checks. b. Preventive maintenance, calibration and safety checks. c. Repair maintenance. 2. Operator Checks – Prior to use on a patient, all equipment will be inspected by the operator of the equipment. Specific inspection criteria is listed in Section A above. 3. Preventive maintenance and calibration – Physical plant equipment, i.e. plumbing, electrical, HVAC is maintained by the owner of the building. Equipment, i.e. laboratory equipment, etc., will be calibrated more frequently if required by law or manufacturers specifications. This maintenance is designed to assure the continued operation and accuracy of all equipment. 4. Repair maintenance – Equipment malfunction will be reported to the Clinic Manager who will see to it that the equipment malfunction is corrected. 5. Maintenance Records – The report will serve as a record of maintenance performed on selected items within the department. Persons performing operational inspections and safety checks; preventive maintenance and calibration; and repair actions will record such actions in each report. Inspections and maintenance will comply with all governing agencies and equipment manufacturers’ recommendations. Data on equipment received between inspections will be maintained with the current inspection for review when necessary.

Lifting and Transfer of Patients 1. Proper techniques will be observed in order to assure the safety of both patients and employees. 19

South Central Kansas Rural Health Clinic

Fire Plan 1. The “Fire Plan” lists actions to be followed by personnel in the event of fire emergency.

Smoking Policy 1. The building housing this Clinic is a “smoke free building”.

New Personnel 1. Personnel assigned to the Clinic will familiarize themselves with all appropriate and applicable policies and procedures immediately following assignment.

Personnel Training 1. The Clinic Manager shall be responsible for training, or assignment to train new personnel. Training will include instructions as to safety and proper operation of clinic equipment. 2. In-Service education of Clinic personnel will be documented. Files will be maintained by the Clinic Manager.

Enforcement 1. The Clinic Manager will be responsible for seeing that the above policies are followed.

Documentation is in Addendum C

South Central Kansas Rural Health Clinic

Drugs and Biologicals Policy

RHC #005

Policy: Drugs and Biologicals Policy All policies concerning drugs and biologicals will be in compliance with all applicable Local, State and Federal laws. All policies will be in compliance with all manufacturerâ&#x20AC;&#x2122;s specifications for labeling, packaging, prescription, storage and disposal. The specific clinic requirements are as follows: A. Storage All drugs and biologicals will be stored in the Manufacturerâ&#x20AC;&#x2122;s containers and dated with the expiration date. All drugs and biologicals will be stored in the appropriate environment, as suggested by the manufacturer. All drugs, except for those in special environment (i.e. refrigeration) are to be secured. All sample medications are to be secured in the appropriate cabinets for employee access only and removed only with the authorization of the appropriate clinical personnel. B. Disposal All drugs will immediately be disposed of properly either in this clinic or at a hospital facility. All drugs and biologicals that are outdated or show signs of deterioration, or are not properly labeled will NOT be used for patient care of dispensed to patients. They will be properly disposed of as outlined above. C. Prescriptions All prescription will be documented in the patient chart indicating drug name, strength, duration and diagnosis. D. Records All appropriate records and logs will be kept in accordance with State and Federal Laws and Regulations. Documentation is under the Temperature Log Tab. 21

South Central Kansas Rural Health Clinic

Medical Records Policy

RHC #006

Policy: Medical Records Policy 3. The medical records for South Central Kansas Rural Health Clinic are to include the following: A. Complete patient identification and social data. B. Evidence of consent forms (when applicable). C. A pertinent medical history. D. Assessment of the health status and health care needs of the patient. E. A brief summary of the episode of care disposition of the patient and instructions to the patient.

4. Also included shall be the report of physical examinations, diagnostic and laboratory test results and the consultative findings. All Physician orders, reports of treatments and medications and other pertinent information necessary to monitor the patient’s progress shall be included. The chart shall also contain the signatures of the Physician or other health care professionals responsible for care. 5. The Office Practice Manager is the designated member of staff responsible for maintaining the records and for ensuring that they are completely and accurately documented, readily accessible and systematically organized. 6. The Clinic will maintain the confidentiality of record information and provide safeguards against loss, destruction or unauthorized use of the medical record. The policies and procedures governing the use and removal of records and the conditions for release of information shall be followed. The patient’s written consent is required for the release of information not authorized by law. 7. In the event that the Clinic is closed, the medical records room will be locked. 8. The Clinic maintains a Records Retention Policy that complies with applicable State and Federal requirements. Inactive patient records will be archived either in the basement or with an alternative service provider. 9. If the record is not used for 3 years, it will be moved to an “inactive file”.

South Central Kansas Rural Health Clinic 10. Upon death of a patient, the record will be moved to a deceased file. 11. Each clinic note will be reviewed by the supervising physician. 12. Medical records will be formally reviewed periodically for quality control. A.

Authorization for Disclosure 1.

Confidential information is defined as all clinical patient data obtained from examination, observation, treatment and conversation with patient or family. Information received from other health care facilities, physicians, etc., regarding the patientâ&#x20AC;&#x2122;s past history or treatment should be used for informational purposes only and should not be released by the receiving clinic except under a specifically worded authorization, court order or subpoena.

Non-confidential information is defined as non-clinical patient data obtained for the purpose of properly identifying the patient. This type of data consists of basic identification, demographic and guarantor information used for planning, billing and research. Examples of data usually considered as non-confidential includes the following: 1. 2. 3. 4. 5. 6. 7.

Patient Name Age Birthday City of residence Date of Service Attending physician Guarantor information

It is the policy of this Clinic to release the above listed non-confidential information at our discretion. Non-confidential information will be released only if the inquiry appears to be legitimate and the release of this information is in the best interest of the Clinic and the patient. Note: Authorizations for information regarding drug/alcohol and AIDS testing are covered under a separate policy. B.

Authorization for Release of Records â&#x20AC;&#x201C; Requirements: 23

South Central Kansas Rural Health Clinic

1. Name of patient. 2. Date(s) of treatment about which information is being requested. 3. Name of party to whom information is to be released. 4. Itemization of information to be released. 5. Specific identification of the institution from which information is being requested. 6. Signature of patient. A. Patient must be competent and or legal age (18 years of age or older, or â&#x20AC;&#x153;emancipatedâ&#x20AC;? by a specific court order; B. If patient is a minor, signature must be that of one of the following in order of rank: 1. A parent. 2. A legal guardian, if one has been appointed (proof should be provided); or 3. Next of kin. 7. Date of authorization: A. Authorization will not be accepted if presented more than 6 months after the date of signature. 8. Expiration or time limit for the authorization.

C. Record of Authorization 1. All patient authorizations shall be kept in the respective records. A notation will be made on the authorization as to what information was released, when it was released, and the initials or signature of the employee handling the request. D. Information to be Released 1. It is the policy of this clinic that progress notes will not be released 24

South Central Kansas Rural Health Clinic without approval of the attending physician. 2. Discretion should be used with the releasing of all medical information even with a signed authorization of the patient. C.

Policy for Disclosure to Patients 1.

The patient or legal guardian should notify the Clinic in writing at least one working day prior to being allowed to review their records.

Patients shall have the right of access of their own health records, unless there are specific contraindications, such as: a. Minors; b. Those deemed legally incompetent; and/or c. Specific restrictions by the attending physician that access could be detrimental to the patient.

The patient will be encouraged to discuss their care with the physician. The attending physician shall be notified when a patient requests access to their record before releasing these records to the patient. This way the physician can advise the Clinic as to whether the patient is capable of reviewing the information. In some instances, records contain information that may be detrimental to the physical and/or mental health of the patient. 3.

A signed and dated authorization shall be required before the patient can review and/or obtain photocopies of the records.

The patient shall be required to pay the charges for copies of the health records. See schedule of charges under External Disclosures.

One the patient has given proper notification, shown proper identification that he/she is that patient and signed an authorization for release of information, he/she can review the health record in the Clinic office. A designee of the Clinic shall remain with the patient until he/she has completed the review. Under no circumstances shall the patient be allowed to remove an original health record from the institution. 25

South Central Kansas Rural Health Clinic 6.

The Clinic Manager shall be notified of all patient’s requests for review of records.

Policy for Internal Disclosure An employee does not have automatic right to access patient records. Access to patient information should be on a “need-to-know” basis whether it is for patient care, peer review or for reimbursement purposes. A.

Administration C. The Clinic Manager or his/her designee has access to patient records whenever necessary to carry out administrative responsibilities. D. The Clinic Manager or his/her designee has the responsibility for final decisions on what medical records disclosures may be made and the circumstances under which disclosure may be made.

Patient Care 1. Use of a patient’s previous health record by physicians and other health care professionals involved in the care of the patient does not require the patient’s signed authorization. 2. If a patient is referred or transferred to another facility, a patient’s signed authorization does not need to be obtained prior to releasing any medical record information. A record should be kept of the information disclosed. 3. When there is a life-threatening need to obtain patient information and there is not sufficient time to send and authorization prior to receiving the information, it is acceptable to obtain the information over the telephone after the call is verified by at least two staff personnel.

Peer Review/Patient Care Evaluation 1. For the purpose of monitoring the quality of patient care provided b the clinic, Administration has the right to access medical record information for patient care evaluation studies. 2. All individual patient identification will be excluded from the routine reports of such findings and recommendations. 26

South Central Kansas Rural Health Clinic F.

Education and Research For the expressed purpose of research and study, medical records may be used without written authorization of the patient. However, every precaution shall be taken to insure confidentiality of the record and the anonymity of the patient.

Legal Counsel Information on records may be furnished to the Clinic’s legal representatives (or insurance carrier) to protect the interest of the clinic in claims involving liability or compensation.

Institutional Affairs 1. Access to the medical record without patient authorization will be provided on a “need-to-know” basis in the management of clinic affairs, including: a. That necessary to performing internal administrative tasks. b. Conducting peer review activities. c. Receiving legal advice. d. Planning health services. e. Surveying clinic approved programs for accreditation compliance. 2. Disclosures of the content of the medical record shall be made only by those suitably trained or qualified to do so. 3. All employees having direct access to patient records shall be instructed in policies on confidentiality and, pursuant to the Clinic’s Employee Handbook, shall be subject to penalties arising from violation of these policies.

Policy on External Disclosure to Third Party Contractors and Insurance Carriers A.

Third Party Contractors

South Central Kansas Rural Health Clinic 1. Certain third party payers are authorized to receive confidential information by virtue of a signed agreement, i.e. Blue Cross/Blue Shield, Medicare, Medicaid, etc.

2. A copy of the most recent of such executed agreements will be kept on file in the Clinic’s billing department. B.

Other Insurance Carriers and Third Party Payers 1. Release of confidential information to insurance companies, or to anyone who has paid or agreed to pay for the patient’s care requires a properly executed authorization. 2. The Clinic’s cooperation in the release of information to insurance companies facilitates proper and prompt payment of claims. Completed insurance forms will not be given to the patient, but mailed directly to the claim-paying agent. 3. Standard information will be released when the phrase, “any and all patient information” or a request is made for the patient complete medical record. This includes a copy of the summary sheet, lab and x-ray with discretion and pertinent information for the claim in question.

Policy on External Disclosure to Other Health Care Institutions 1. In cases of direct patient transfer to other institutions, information as is necessary to provide continuity of care shall be photocopied by appropriate personnel or by an outside service. These copies shall either be given to the patient for delivery to the requesting institution or shall be transmitted electronically by the Clinic if possible, or through a third party service. 2. Requests from other facilities for confidential information requires proper authorization. a. In the event that a delay in the release of confidential information would be injurious to the patient, the information shall be provided in the most expeditious manner possible. The requesting institution shall be instructed to send the proper authorization one week in advance.

South Central Kansas Rural Health Clinic b. If the delay would not be injurious to the patient, such as request for records in advance of an admission, the requesting institution must send the request in writing accompanied by the authorization. c. If time does not permit for mailing of information, the copies shall be placed in a sealed envelope and given to the patient to deliver, or arrangements will be made to transmit the information electronically. 3. All reasonable consideration will be shown to these health care institutions. However, the interest of the clinic and the patient must be observed. 4. There is no charge for records being sent to other health care institutions. K.

Policy on External Disclosure to Other Physicians (Individual & Group Practices) 1.

Release of confidential information to physicians not on the Medical Staff requires proper authorization.

Release to Active Medical Staff may be done without the written authorization of the patient if the staff member is involved in the patient’s care.

Release to Courtesy and Consulting Staff shall be a follows: a. Basic information required by the courtesy staff when performing either a consultation or surgery, shall be released without patient authorization. b. Requests made by courtesy staff for information for the purpose of taking over the patient’s medical care in their facility, will required patient’s authorization. c. Release of results of tests that they have ordered to be performed in this clinic does not need patient authorization. d. Request made for patient records by consulting staff shall require patient’s authorization.

Requests made by the attending physician for records to be sent to another physician shall be released only with written patient authorization.

South Central Kansas Rural Health Clinic a.

All efforts should be made to sent this information by mail or electronically. However, in the event if circumstances do not allow for mailing or electronic transmission this information, the patient may hand carry it. The information should then be placed in a sealed envelope.

5. There is no charge to the patient for records being sent to other physicians. L.

Policy on External Disclosures (Attorneys) 1.

Attorneys must provide proper written authorization in order to obtain patient information. Request for copies of an entire medical record is discouraged.

An exception to this practice is the Clinic’s outside legal counsel. Whenever the clinic’s legal representatives are coordinating a legal matter with other attorneys, such as those representing a physician, the needed copies of records shall be provided without authorization and without charge.

The attending physician will be notified anytime a request is received from an attorney.

Attorneys will be charged according to the applicable fee schedule.

Policy on External Disclosure (Governmental Agencies)

The Draft Board, Veterans Administration, Department of Health and Human Services, Social Security Administration, National labor Relations Board, and Railroad Retirement Commission have the authority to issue subpoena’s to obtain medical information. In the absence of a proper subpoena or other legal documents, a properly executed authorization is required.

Policy on External Disclosure (Medical Examiner/Coroner)

Pertinent medical information may be released without authorization to a medical examiner/coroner if the patient’s death is under review by this official.

South Central Kansas Rural Health Clinic O.

Policy on External Disclosure (Evidence and Investigation) 1. Confidential information shall only be released to officers of the court or government investigation and law enforcement agencies if disclosure is authorized by the patient or compelled by a proper judicial subpoena, court order or as otherwise mandated by law. A patient’s right to privacy is not waived automatically as a result of or in response to investigations.

Subpoenas will be reviewed and verified. Proper blanket subpoenas for all patient’s records do not waive the patient’s privilege for all records, but merely those relevant to the condition in question. If the medical record contains information regarding treatment on several occasions for several conditions, care should be exercised in providing the documents by affidavit unless the patient’s attorney is aware that the disclosure will be made.

If the patient is not a party to the action, the patient should consult legal counsel.

Policy in Response to Subpoenas and Court Orders A.

Subpoenas 1. When the Clinic and other health care providers receive subpoenas, they are generally of two types: a.

Deposition subpoena – directs a person to appear and provide sworn testimony such as at a trial or deposition.

Subpoena ducestecum – commands a person to appear, provide sworn testimony and to bring documents, records, etc. identified in the subpoena.

2. A subpoena for a deposition in a KansasState court action may be issued by the court reporter or the Clerk of the Court. In Federal actions, only the Clerk of the court may issue subpoenas for depositions. In a worker’s compensation action or other administrative proceeding, a subpoena may be issued by the Administrative Law Judge. The clinic strongly recommends that legal counsel be consulted upon receipt of any subpoena.

South Central Kansas Rural Health Clinic 3. Subpoenas may be served upon the custodian by law enforcement officials, attorneys, court clerks as well as private detectives. In general, the credentials of the server are less of an issue than the content and validity of the subpoena. 4. Usually a valid subpoena will contain:

a. b.

Name of the Court. Names of the plaintiff and defendant.

Docket number of the case.

Date, time and location of requested appearance.

Specific documents sought.

Name, address, and telephone number of the attorney requesting the subpoena.

Signature or stamp and seal of the appropriate official.

5. In certain circumstances, a subpoena must be accompanied by a witness fee as established by applicable law. You should contact the appropriate Court Clerkâ&#x20AC;&#x2122;s office to determine what fee, if any, is applicable. 6. Some subpoenas are invalid due to lack of jurisdiction by the issuing court. As a general rule, any county or state court within Kansas will have jurisdiction to issue a subpoena anywhere within Kansas. However, a person is not required to attend an examination at the place which is not within 50 miles of the witnessâ&#x20AC;&#x2122; residence, place of employment or principal place of business. A state or county court outside Kansas has no jurisdiction to issue a subpoena in Kansas. County courts will have jurisdiction to issue a subpoena only within the confines of that County. United States District courts have jurisdiction to issue a subpoena within their district or a 100 mile radius, whichever is greater. 7. Another factor which may affect the enforceability of a subpoena is its timeliness. For example, if a subpoena commands an appearance in less than 24 hours and the deponent is able to demonstrate undue hardship in complying with the subpoena, the subpoena could be quashed by the Court. In such cases where an unreasonable amount 32

South Central Kansas Rural Health Clinic of time has been given to comply with counsel or, alternatively, the court to reschedule the requested appearance. 8. If a subpoena is believed to be invalid, for whatever reason, the attorney or party that caused the subpoena to be issue should be notified as soon as possible. Legal counsel also should be notified of any steps taken by the deponent to quash the subpoena or court order. 9. Failure to comply with a proper subpoena could result in sanctions ordered by the court, such as payment of the issuing counsel’s attorneys’ fees and costs in enforcing the subpoena. 10. When documents are requested, a number of steps should be taken in order to prepare for the production of those documents: a.

Read the subpoena and the document request very carefully. The deponent is only obligated to produce documents that are relevant to the subject matter of the lawsuit and those likely to lead to the discovery of admissible evidence. Further, the deponent is not obligated to produce documents that are not requested. Also, unless specifically identified in the subpoena, remove all “unnecessary” documents, i.e. correspondence, duplicate copies of reports, insurance reports, billing related information, etc.

Locate the record and ensure it is complete and that each page belongs in that particular record. If the record is incomplete, obtain the missing documents or be prepared to explain why they are missing.

Obtain any additional records specified in the subpoena, i.e. itemized statements, x-ray films, etc.

Become familiar with the record to be produced and its contents.

If the record is on microfilm or electronic media, notify the issuing attorney. The attorney may choose to utilize the appropriate equipment at the deposition or in the courtroom, or pay for having the records reproduced in hard copy. Microfilm and electronic records in lieu of originals are admissible under the Federal Rules of Evidence.

South Central Kansas Rural Health Clinic f.

Number each page (front and back), top right hand corner of the record in ink and record the total number of pages on the record envelope

The entire record should be photocopied and a written statement prepared that establishes that the copy id an exact duplicate of the original.

It is generally a good practice once a subpoena is received that the corresponding health records and photocopies be placed in a sealed envelope and not opened until delivered to and authorized by the court. A valid exception, of course, is the necessary use of the records for patient care should the patient present for treatment. When the record is needed for patient care, it is recommended that a copy of the records be made and sent for access.

11. Once a record is the subject of possible or threatened litigation, whether or a not a lawsuit has been filed, the applicable records should be removed immediately from the active files and locked in a secure area. 12. Physicians, nurses and others involved in the applicable treatment of that patient may want to review the record to refresh their memory. Review of the record is acceptable as long as the review takes place within a secure area in the Clinic. All such requests must be submitted to the Administrator of the Clinic or his/her designee. Copies will not be made without proper subpoena, court order or patient authorization. B.

Court Orders 1. A court order directs the recipient to respond or perform or stop performing in a certain way. 2. If the institution or individual receives a court order but believes that compliance with same would violate a specific statute or regulation, the court order may be contested before any sanctions for failure to comply are imposed. Once a final decision is rendered on the court orderâ&#x20AC;&#x2122;s validity, the recipient must act accordingly. 3. A question that frequently arises concerns the â&#x20AC;&#x153;life spanâ&#x20AC;? of a court order, i.e. the length of time for which it is valid. The answer is simple; there is no set time limit. So long as the respective case is open and still before the issuing court, the court order is valid.

South Central Kansas Rural Health Clinic 1. The method for preparing the records for court in response to a court order as opposed to a subpoena should not differ, unless so stipulated in the court order. C.

Affidavits:

An affidavit is a statement written down and sworn to be true. An affidavit can be used in lieu of appearance of a witness court. The affidavit cannot be used if the subpoena ducestecum contains the following statement: â&#x20AC;&#x153;The personal attendance of a custodian of business records and the production of original records is required by this subpoena. The procedure for delivering copies of the records to the Clerk or Court shall not be deemed sufficient compliance with this subpoena and should be disregarded. A custodian of the records must personally appear with the original recordsâ&#x20AC;?. If the affidavit is used, it must accompany the copies of the records described in the subpoena and must include the following information: (1) The affiant is a duly authorized custodian of the records and has authority to certify records; (2) The copy is a true copy of all records described in the subpoena; and (3) The records were prepared by the personnel or staff of business or persons acting under their control in the regular course of business at or about the time of the act, condition or event recorded. The advantage of using an affidavit is not having to spend time in court. Q.

Policy on External Disclosure (Fees for photocopies)

Pursuant to K.S.A. 65-4971, the minimum charge for photocopies of medical records, other than workers compensation medical records, is currently $15.75, plus $0.52 per page for the first 250 pages and $0.36 per page for additional pages, with the patientâ&#x20AC;&#x2122;s authorization to : lawyers, insurance companies, and other non-health care provider third parties.

For workers compensation medical records the current charge is $16.00 for up to 10 pages; $28.00 for up 11-50 pages; and $28.00 plus $0.35 for each additional page above 50. The above referenced rates shall be adjusted from time to time as appropriate. Minimum charge for: Disability Determination Service $25.00 for photocopies

South Central Kansas Rural Health Clinic $30.00 for narrative No charge for photocopies sent to other physicians upon their request or the patientâ&#x20AC;&#x2122;s request, as this is a professional courtesy. R.

Policy for Requests for Correction or Amendment to the Medical Record 1.

A patientâ&#x20AC;&#x2122;s request for correction or amendment to the health record shall be submitted in writing and shall specify the entry or entries in dispute. With the exception of requests for correction of such items as time of admission, birth date, spelling of name and other such admission data that can be handled by qualified employees, the attending physician shall be notified of any such request for corrections or amendments. The individuals who made the entry shall also be involved in the discussion. The individual making the entry, along with the attending physician and the institution, shall then decide whether or not the correction or amendment is to be allowed.

If the decision is made to correct or amend the record, the patient shall be so advised. Any correction or amendment shall be made in such a manner as to not obliterate the material present in the health record. Any corrections that are of a significant nature shall be sent to any party that may have copies of this information, i.e. physicians, other health care institutions, etc.

3. If the request for correction or amendment is not granted, the patient shall be informed that a statement of the patientâ&#x20AC;&#x2122; s disagreement can be filed with the health care institution and that the disputed entries in the health record will be appropriately annotated to reflect this disagreement. Any further disclosure of the health record shall include this statement of disagreement and the annotations.

Documentation for Medical Records is located under the Medical Records Tab.

South Central Kansas Rural Health Clinic

Patient Care Policy 1.

RHC #007

Rural Health Clinic Services Policy

It shall be the policy of South Central Kansas Rural Health Clinic and pursuant to the Rural health Clinic Agreement, this Clinic provides primary health care to its patients. These services include but may not be limited to the list below. Depending on the skill level of the Provider and availability of equipment or service: a. b. c. d. e. f. g. h. i. j. k. l. m.

Medical history physical examination assessment of health status treatment of medical conditions Injections Medications Laboratory tests Vaccines for children Screening and treatment of childhood obesity Asthma assessment and treatment Hysteroscopy Implanon CMG

n. Fracture Care o. Minor Surgeries p. Laceration Repair q. Colposcopy r. Uterine Ablation s. Sterilization t. Digital X-Ray u. Sonography v. Bone Densitometry w. PFT Spirometry y. Tympanometry z. EKG aa. 1st Trimester OB bb. Endometrial Biopsy cc. Respiratory or nebulizer treatment dd. Holter Monitor

Any special procedures or care beyond the Clinicâ&#x20AC;&#x2122;s capabilities will be performed outside this Clinic in an appropriate inpatient/outpatient hospital or clinic setting, or within the clinic as services not covered under the Rural Health Clinic program.

South Central Kansas Rural Health Clinic Such services include but may not be limited to the list below. Depending on the skill level of the Provider and availability of equipment or service: : a. b. c. d. e. f. g. h. i. j. k. l. m. n. o. p. q. r. 2.

OB/GYN Major and minor surgery Radiology Complicated lacerations Castings Emergency care Lesion removal Nerve conduction testing Endoscopy Colonoscopy Sigmoidoscopy Hospital services Chemotherapy Cardiology Treadmills Holter monitors Moderate and complex lab procedures Critical care RURAL HEALTH CLINIC LABORATORY SERVICES 1.

Delineation of Services:

Through its agreement with South Central Kansas Medical Center, the clinic offers on-site, CLIA certified laboratory services essential to the immediate diagnosis and treatment of the patient, including: A.

Chemical examination of urine by stick including urine keytones;

Hematocrit;

Blood sugar;

Examination of stool specimens for occult blood;

Pregnancy tests; and 38

South Central Kansas Rural Health Clinic

Primary culturing for transmittal to a certified laboratory. 2.

Primary Culturing for Transmittal

Despite the time and complexity, the isolation of the etiologic agent by cultivation in artificial media, tissue cultures, or animals is generally the most definitive procedure available. The diagnostic value of a culture specimen, however, depends to a large extent on the likelihood that it has been collected free of contamination with the resident microbial flora and transported to the laboratory in a fashion that ensures survival of fastidious organisms. A.

Specimen collection 1. When specimens from deep closed lesions are collected, the site of percutaneous needle aspiration should be cleansed first by using 70% isopropyl or ethyl alcohol and then disinfected with a 2% tincture of iodine or an appropriate iodophor. The iodine is applied in a concentric fashion beginning at the site of aspiration is performed. The area should not be probed or manipulated unless sterile gloves are worn or the involved fingers have also been disinfected. If the initial attempt at collection fails, subsequent efforts should be carried out with a new needle though a freshly disinfected site. At the completion of the procedure, the iodine should be removed with alcohol to avoid the danger of sensitization. If the specimen for culture is drawn through and indwelling cannula, the site of withdrawal must be disinfected. 2. When specimens are to be collected from the uterus or a draining would or sinus tract, the orifice must be thoroughly cleansed and disinfected as described above, a sterile intravenous catheter or multilumen tube is introduced as deeply as possible through the orifice, and the specimen aspirated into a sterile syringe. Culture from an open lesion may be collected by biopsy, aspiration from the margin, or by swabbing the surface. In the first two situations the wound is prepared as for a deep closed lesion. For swab cultures, the wound surface is cleansed only with sterile saline to remove debris and saprophytic flora.

Transportation 1. All specimens submitted for microbial culture should be transported to the laboratory as rapidly as possible, preferable within 24 hours. Delay beyond this may result in death of fastidious organisms, overgrowth of contaminants, and/or change in the number of bacteria unless special procedures are employed to overcome these problems. Rapid transportation is particularly important when dealing with blood, body fluids, and exudates which may harbor pathogenic 39

South Central Kansas Rural Health Clinic neisseria or anaerobes. The container should be clean, sterile (stool specimen expected), and appropriately labeled. 2. Respiratory secretions, urine, large pieces of tissue, and large volumes of fluid can be safely transmitted in plastic containers with leak proof lids. Aspirates are conveniently and safely transported in the same syringe used in the same syringe used in the collection procedure, providing all air is express from the syringe and the needle is capped with a sterile holder. Alternatively, such fluid may be injected into a sealed gassed- out vial suitable for transport of anaerobic specimens. If such vials are used, it is important that the indicator in the vial be checked to ascertain whether it is still colorless. A pink or blue color indicates the presence of oxygen and suggests that the vial is no longer adequate for the transport of specimens for anaerobic culture. Small pieces of tissue (less than 1 cm) are transported best in sterile rubber stopper gassed-out tubes. After the anaerobic indicator is checked, the tube is held upright to minimize the loss of the heavy inert gas, the stopper removed, specimen inserted, and the tube recapped. 3. Swabs submitted for the culture of group A beta=hemolytic streptococci can be transported in dry sterile test tubes. All other swabs should be submitted in one of several commercially available transport media. These prevent both the desiccation of organisms implanted on the swab and the overgrowth of hardy organisms at the expense of more fastidious ones. Although special anaerobic transport materials are available, use of swab cultures for the recovery of such organisms is not encouraged. C.

Hand/Mouth Contract Employees that handle biohazards must be well aware of the hand/mouth mode of contracting diseases. Employees must never eat, drink, take medications, apply cosmetics, smoke, mouth pipette and/or place any item from a work surface into the mouth, including fingers.

Handwashing Employees handling biohazards are required to wash their hands with an appropriate soap solution that is all hand washing sinks for frequent use.

Work Surfaces Work surfaces where biohazards are handled are decontaminated after each spill and routinely once a day. The disinfectant currently in use should be used for this purpose. 40

South Central Kansas Rural Health Clinic

Specimen Labeling All specimens identified as being from a suspected or known infectious patient (Hepatitis, AIDS, etc.) must be distinctively labeled. Subdivision of these specimens must also be distinctively labeled.

Sample Disposal All biohazard samples (Hepatitis, AIDS, and/or microbiological samples) and/or disposable contact materials must be placed in double bags prior to disposal.

Clothing Clothing must provide adequate coverage and be appropriate for the work area.

Shoe Requirements Shoes shall be adequate to meet safety requirements: a. Open toed and sandal shoes are prohibited in lab.

b. Open heeled shoes are acceptable only if the shoes are firmly secured around the ankle or heel, and the heels are one inch above the floor. Loose clog type shoes are unacceptable. Cosmetics The application of cosmetics is prohibited in any area used for receiving, storing, handling and/or testing of laboratory specimens and/or chemicals or where otherwise prohibited.

Beverages Beverages preparation, storage or consumption is prohibited in any area used permanently or temporarily for receiving, storing, handling or testing laboratory specimens and/or chemicals.

South Central Kansas Rural Health Clinic Beverages shall not be in refrigerators or freezers that contain or have contained laboratory specimens or chemicals. Drinking from laboratory glassware is prohibited. 3.

Medical Management of Health Care Problems A. All records will be retained in the patient files per South Central Kansas Rural Health Clinic retention guidelines. B. All consultations and referrals will be made by the physician assistant or after consultation with the physician, and such consultation and/or referral will be entered on the patient records. C. The clinic shall provide medical emergency procedures as a first response to common life-threatening injuries and acute illnesses. The Clinic and Clinic employees may be asked to handle a medical emergency. This is a situation we hope will never occur but one that must be prepared for to obtain the best possible results. Medical Emergencies 1. The clinic medical staff will be notified immediately. (Physician, Physician Assistant, and Medical Assistants) 2. Clinical staff will execute and follow orders as directed by the medical professional tending to the patient. 3. Patients and visitors will be isolated and removed from the area. 4. Trained personnel will use life saving techniques while waiting for help to arrive.

Equipment 1. The Clinic will have emergency drug, equipment box, AED and emergency cart available. 2. The Clinic will have emergency oxygen available. 3. The Clinic will have emergency numbers readily available. 42

South Central Kansas Rural Health Clinic 4. The Clinic will have the resources and cooperation of the Hospitals.

Training 1. All Clinic employees are encouraged to become certified in CPR. 2. All medical professional are expected to maintain and/or get certified with CPR and additional techniques of emergency medical training. 3. All employees will be trained the procedure to use in the event of a medical emergency. Working Arrangement D. It shall be the policy of South Central Kansas Rural Health Clinic to provide the following services through agreement or arrangement with local hospitals and/or clinic centers.

1. The working arrangement between South Central Kansas Rural Health Clinic, and the two area hospitals, William Newton Memorial Hospital and South Central Kansas Regional Medical Center (Hospitals), is evidenced by and consists of years of patient medical treatment and care, and coordination of the best delivery of patient care. Through this long-term relationship between the Clinic and the Hospitals, the parties continue to demonstrate that the following framework of that relationship is equitable and beneficial for both entities. 2. Conditions of Understanding Patient Referral: The Hospitals accept patient care referrals from the Clinic for medical care services outside the scope of the Clinicâ&#x20AC;&#x2122;s practice. The services include but are not limited to, hospital care/stay, emergency services, selected surgeries and surgical procedures, selected diagnostic testing, and procedures allowed under applicable Federal, State and Local laws and licensure requirements and abilities of the Hospital. Medical Records: The Clinic and the Hospitals maintain continuity and confidentiality of medical records in compliance with applicable Federal and State laws as well as regulations governing Rural Health Clinic acts. 43

South Central Kansas Rural Health Clinic

Patient Notice

RHC #008

Medicare will only pay for services that it determines to be “reasonable and necessary” under Section 1862 (a) (1) of the Medicare Law. If Medicare determines that a particular service, although it would otherwise be covered, is “not reasonable and necessary” under Medicare Program Standards, Medicare will deny payment for that services. I believe that, in your case, Medicare is likely to deny payment for: ______________________________________________________________________________ ______________________________________________________________ (Specify particular services)

for the following reasons: _________________________________________________ ______________________________________________________________________ (Give your reason(s) for your belief)

Beneficiary Agreement

“I have been notified by my physician that he or she believes that, in my case, Medicare is likely to deny payment for the services identified above, for the reasons stated. If Medicare denies payment, I agree to personally and fully responsible for payment”.

Signed: __________________________________Date: _______________________ (Beneficiary)

South Central Kansas Rural Health Clinic

South Central Kansas Rural Health Clinic is dedicated to the delivery of the highest level of healthcare possible and to the health and well being of our patients and their families. We will provide our services regardless of race, color, creed, age, national origin or handicap. We believe that all persons have equal right to medical care of the highest quality to restore and maintain health and preserve life. The health, comfort, well-being and safety of our patients are our utmost concern. It is the clinicâ&#x20AC;&#x2122;s philosophy that quality patient care cannot be achieved except through welltrained, satisfied and dedicated employees. All applicants and employees will be given equal consideration regardless of race, creed, color, age, marital status, sex, handicap or national origin. We strive to employ those individuals who are the best qualified and most capable of performing all duties required in each specific position being considered.

South Central Kansas Rural Health Clinic

Job Descriptions Job Title: Clinic Medical Director

RHC #010 Employee Name:Dr Karman Shazada

Reports To: CEO

Department: Rural Health Clinic

Date of Employment:

Review Date:

1. Provides physician services to patients of the clinic. 2. Is available for consultation, assistance with medical emergencies, and consultation/referral by the mid-level practitioner. 3. Assists with development, implementation, and periodic review of RHC policies, protocols, and collaborative practice agreements. 4. Reviews and co-signs all patient records (if required) containing orders for prescription drugs and others as stipulated in clinic policies and procedures. 5. Participates in Annual Report development and QI activities 6. Ensures the maintenance of current DEA certificates in clinic personnel files. 7. Participates in chart audits as required by RHC regulations. 8. Provides medical director services to all components of the Rural Health Clinic. 9. Completes monthly Time-keeping records as needed. 10. Provides medical supervision of all clinic medical staff including mid-level practitioners as needed. 11. Complies with all appropriate requirements for clinic quality assurance and certification. 12. Maintains licensure and board certification. 13. Maintains current PALS certification. 14. Demonstrates clear written and verbal communication skills. 46

Action Needed

Area for Improvemen Meets t Expectations

I. Essential Duties and Responsibilities

Exceeds Expectations

Coordinates medical care of clinic patients and ensures the quality of medical care provided within the clinic. Provides oversight of overall clinical operations.

Outstanding

POSITION SUMMARY:

Pay Type:

South Central Kansas Rural Health Clinic 15. Effectively interacts with a variety of individuals on a wide range of topics. Additional Duties 16. Performs other duties as assigned. Total: Average: *Duties in bold type indicate mandated functions

Comments:

Educational Qualifications:  Doctor of Medicine or Doctor of Osteopathic Medicine degree from accredited United StatesMedicalSchool. Must be licensed to practice medicine in State of Kansas prior to beginning employment.  Current physician licensure in the State of Kansas.  Completion of residency required. At least five years in Rural Health practice preferred. Applicant may not have any unresolved malpractice suits pending against him/her and shall not have any unresolved complaints on file in any state where he/she has license to practice medicine.  Computer literacy required. Work Relationship:  Reports directly to the Chief Executive Officer.  Works closely with employees within department and throughout facility.  Frequent contact with patients and families. 47

South Central Kansas Rural Health Clinic  Occasional contact with vendors, public, civic organizations, regulatory agencies and other provider organizations. Working Conditions:  Work is performed within a medical clinic environment.  Regularly exposed to hazardous materials such as needle puncture, blood and body fluids.  Occasionally exposed to fumes or airborne particles, toxic or caustic chemicals. Physical Requirements:  Frequent standing, walking, bending twisting, kneeling/squatting, grasping, and manual/fine dexterity.  Near/far vision.  Ability to hear-close distance.  Occasional sitting, driving and reaching.  Ability to lift/carry and push/pull up to 50 lbs Acknowledgement: This job description/evaluation describes the general nature and level of work performed by an employee assigned to this position. It does not state or imply that these are the only duties and responsibilities assigned to the job. The employee may be required to perform other job-related duties as requested by the department manager or administration. All requirements are subject to change over time and to possible modification to reasonably accommodate individuals with disabilities.

Employee Signature

Date

South Central Kansas Rural Health Clinic Position: Clinic Manager Description / Responsibilities: The Clinic Manager is responsible for overseeing the medical and administrative operations of the organization’s clinics, and for supervising both clinical and administrative staff. The role of the Clinic Manager includes the selections, supervision and evaluation of medical staff such as physicians and medical support staff as well as administrative employees such as receptionists, billing clerks and medical coders. Additional Duties include: 

Understanding and managing the entire revenue cycle process, from scheduling to billing and payment audits.



Handling patient concerns/complaints



Maintaining compliance with applicable federal, state and local regulatory requirements



Maintaining and establishing policies and procedures related to the medical practices



Work with South Central Kansas Medical Center (SCKMC) financial department to review operations and monthly reporting requirements



Work with SCKMC quality department to facilitate compliance with Physician Quality Reporting



Organizing and conducting meetings related to practice performance and operational changes that may impact the practice



Maintains a safe working environment for the staff as well as for the patients and family members.



Maintains confidentiality of patients.

Completes other duties as assigned. Requirements:  Bachelor’s Degree in Business or Health Administration  Healthcare experience – 7 years Reporting Relationship: Manager: Immediate Reports: Interrelationships:

Chief Executive Officer Chief Executive Officer / Chief Financial Officer Will work closely with all clinic staff and patient families.

Working Conditions: Job responsibilities require occasional exposure to noise, lighting and/or temperature levels. Exposure to irritating, unpleasant or hazardous elements or conditions (i.e. bloods, chemicals and infectious diseases) is frequent. Work will be subject to frequent interruptions from patients and 49

South Central Kansas Rural Health Clinic staff. Work schedule will be Monday thru Friday 8:00am to 5:00pm and will be subject to irregular working hours.

I have read the position description and essential physical requirements. I am able to perform the essential physical requirements and the position description with or without accommodations.

Applicant or Employee Signature

Date

Department Manager or Interviewer Signature

Date

South Central Kansas Rural Health Clinic Position: Nursing Description / Responsibilities:                 

Provides direct and personalized care to patients. Documents and executes the Physicians orders as per policy/standards of the facility. Takes and records temperatures, pulse, respiration, weigh, height and blood pressure per protocol. Performing EKG’s, PFT’s, X-rays, Inhalation treatments, collection of specimen & performing drug screens, Prepares, administers and records medications in accordance with the policy regarding the administration of medicine. Drawing blood and filling out requistions Serve as a chaperon to the Physician in the patient room. Responds and participates in emergency care as directed by Physician. Performs and completes data history for range of patients served in a timely manner and in accordance with policy. Communicates with patients in a professional manner. Responds to patient and other physician requests in professional and timely manner. Answers phones, refers appropriate messages in a timely manner, and keeps office area tidy and organized. Coordinate with SCKMC Central Scheduling for patient testing. Calls in prescriptions for patients. Coordinate with Clinic Manager to ensure supplies are adequate. Ensures office and clinic equipment is operational. Maintains confidentiality of patients. Maintains a professional appearance. Completes other duties as assigned.

Qualifications: License: LPN or RN in the state of Kansas. Certifications: CPR. IV Certification from an accredited nursing school. Education: Must maintain license by meeting the Kansas licensing board CEU requirements. Experience: 5 plus years of experience Other: Must be highly organized, must be an independent thinker with the ability to learn quickly. Bilingual ability is a plus. Reporting Relationship: Manager: Immediate Reports: Interrelationships:

Physican / Clinic Manager Chief Executive Officer Will work closely with all clinic staff and patient families.

South Central Kansas Rural Health Clinic staff. Work schedule will be Monday thru Friday 8:00am to 5:00pm and will be subject to irregular working hours.

I have read the position description and essential physical requirements. I am able to perform the essential physical requirements and the position description with or without accommodations.

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South Central Kansas Rural Health Clinic Position: Patient Services Technician Description / Responsibilities: Working across the whole clinic, services will be provided to the patients of all providers. Collaborating with all staff the activities will include: 

Drawing labs for most patients, demonstrating skill with patients ranging in age from newborn to geriatric,

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Administering the Vaccines for Children (VFC) Program and the private vaccines

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Working with providers and other staff to schedule referrals to other physicians, for studies, tests etc. One arranged those requiring preauthorization will be forward to "front" staff.

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Provide support to staff to obtain prior authorizations for medications.

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Perform EKGs, PFT, Osteoporosis testing

Maintains a safe working environment for the staff as well as for the patients and family members. Demonstrates support to other team members and nursing staff to create a system of quality care. Communicates with patients in a professional manner. Maintains confidentiality of patients. Maintains a professional appearance. Completes other duties as assigned. Reporting Relationship: Manager: Immediate Reports: Interrelationships:

Physician Clinic Manager / Chief Executive Officer Will work closely with all clinic staff and patient families.

Working Conditions: Works in patient care area 100% of the time. Job responsibilities require occasional exposure to noise, lighting and/or temperature levels. Exposure to irritating, unpleasant or hazardous elements or conditions (i.e. bloods, chemicals and infectious diseases) is frequent. Work will be subject to frequent interruptions from patients and staff. Work schedule will be Monday thru Friday 8:30am to 4:30pm and will be subject to irregular working hours.

I have read the position description and essential physical requirements. I am able to perform the essential physical requirements and the position description with or without accommodations. 53

South Central Kansas Rural Health Clinic

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South Central Kansas Rural Health Clinic Position: Receptionist Description / Responsibilities: General office duties including but not limited to answering phones, faxing, copying, filing, data entry, greeting patients and helping them, scheduling appointments, maintaining records, collect and record payments Job Duties:  Welcomes patients and visitors by greeting them in person or on the telephone in a manner that is helpful and friendly.  When scheduling appointments carefully screens patients for correct demographic information, determine if new patient visit and informs patient of adequate items/payments that must be presented at time of visit.  Optimizes patients’ satisfaction, provider time, and procedure room utilization by scheduling appointments according to physician time preferences.  Provides information to Clinic callers according to the Clinic’s Policies and Procedures.  Keep patients appointments on schedule by notifying provider of patient’s arrival.  Maintains patient accounts by obtaining, recording, and updating personal and financial information.  Exhibit flexibility and a Can-Do attitude when collaborating with Clinical staff on scheduling changes  Calls patients daily to confirm next day’s appointments.  Exercises problem-solving and conflict resolution skills when handling patient complaints; refers patient complaints to appropriate designated personnel  Prepare needed paperwork to be completed by patient.  Record and collect patient payments and co-pay amounts due at time of service.  Maintain business office inventory by checking stock; anticipate needed supplies and report needed items for ordering to clinic manager.  Submit electronic or handwritten messaging requests  Protect patients’ rights by maintaining confidentiality of personal and financial information.  Attends scheduled department staff meetings  Performs other duties as may be required Skills and Qualifications:  Understands the importance of maintaining confidentiality; HIPAA standards.  Must have excellent customer service and interpersonal communication skills.  Intermediate to advanced phone skills; able to effectively relate via the telephone and inperson to serve the needs of the patients/visitors in a manner that is efficient and productive.  Well developed verbal and written communications skills.  Ability to work well under pressure with minimal supervision. Willingness to handle a variety of tasks.  Time management, Organization, Attention to Detail, Professionalism, and Quality Focus 55

South Central Kansas Rural Health Clinic Specific Clinic Policies for scheduling, prescription requests, electronic messaging: Dr. Shahzada- Day out is Friday â&#x20AC;&#x201C;schedule runs from 10:00am-4:30pm Established Patient 15min Workmanâ&#x20AC;&#x2122;s Comp 15 min New Patient 30 min WWE/WME 30 min Procedure 30 min Random Drug Screen 10 min (schedule for nurse BEFORE 10:00am) Lab work 5 min (can be double booked) Allergy Shots 5 min (can be double booked) Other Shots 5 min (can be double booked) Holter hookup 5 min (can be double booked) Let Naghma know Reporting Relationship: Manager: Immediate Reports: Interrelationships:

Clinic Manager Clinic Manager / Chief Executive Officer Will work closely with all clinic staff and patient families.

Working Conditions: Works in patient care area 100% of the time. Job responsibilities require occasional exposure to noise, lighting and/or temperature levels. Exposure to irritating, unpleasant or hazardous elements or conditions (i.e. bloods, chemicals and infectious diseases) is frequent. Work will be subject to frequent interruptions from patients and staff. Work schedule will be Monday thru Friday 8:00am to 5:00pm and will be subject to irregular working hours. I have read the position description and essential physical requirements. I am able to perform the essential physical requirements and the position description with or without accommodations.

Applicant or Employee Signature

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South Central Kansas Rural Health Clinic

Annual Evaluation A.

RHC #011

On annual basis the Clinic shall hold an evaluation of its total program. The evaluation will include: 1. Review of the utilization of Clinic Services, including services rendered to at least ten patients and ten different services. 2. Review of a representative sample of both active and closed clinical records. 3. Review and revise as needed the Clinicâ&#x20AC;&#x2122;s health care policies.

The purpose of the evaluation shall be to determine if the utilization of services was appropriate, the established policies were followed, and if any changes are needed. Corrective actions and policy revisions will be made as the findings of the review warrant.

Bad Debt Policy 1.0

RHC #012

Bad Debt Policy 1.0.1 It is the policy of South Central Kansas Rural Health Clinic to ensure that debts owed by patients for medical care delivered by South Central Kansas Rural Health Clinic. are collected in a timely manner. Payment of such debts will be pursued according to uniform criteria and procedures applicable to all South Central Kansas Rural Health Clinic patients to ensure that Medicare will provide cost reimbursement to South Central Kansas Rural Health Clinic for that portion of any uncollectible bad debt attributable to Medicare beneficiaries.

2.0

General Information 2.0.1 Costs attributable to the deductible and coinsurance amounts owed by Medicare beneficiaries that remain unpaid are added to the Medicare share of allowable costs and are reimbursed under the federal Medicare program. Bad debts arising from other sources are not allowable costs for purposes of Medicare.

3.0

Definitions 57

South Central Kansas Rural Health Clinic 3.0.1 Bad Debt: Bad debts are amounts considered to be uncollectible from accounts and notes receivable that were created or acquired in providing healthcare services. “Accounts Receivable” and “Notes Receivable” are designations for claims arising from the furnishing of services and are collectible in money in the relatively near future. 3.0.2 Deductibles and Coinsurance: Deductibles and coinsurance are amounts payable by Medicare beneficiaries for covered medical services. 4.0

Criteria for Allowable Bad Debt 4.0.1 Under the Federal Medicare program, costs of covered services furnished to Medicare beneficiaries are not to be carried by individuals not covered by the Medicare program. Conversely, the costs of services provided for non-Medicare beneficiaries are not be carried by the Medicare program. 4.0.2 The failure of Medicare beneficiaries to pay the deductible and coinsurance amounts could result in the related costs of covered services being carried by other than Medicare beneficiaries. 4.0.3 In determining whether unrecovered costs of covered services are due to bad debts, the Medicare program is considered as a whole without distinction between Part A. 4.0.4 A Medicare bad debt must meet the following criteria to be allowable: a.

The debt must be related to covered services and derived from deductible and coinsurance amounts;

The provider must be able to establish that reasonable collection efforts were made;

The debt was actually uncollectible when claimed as worthless; and

Sound business judgment established that there was no likelihood of recovery at any time in the future; or

The patient has applied for and been approved for financial assistance under the SCKMC/SCKC Rural Health Clinic policies. 58

South Central Kansas Rural Health Clinic

5.0

Charging of Bad Debts and Bad Debt Recoveries 5.0.1 The amounts uncollectible from Medicare beneficiaries for charges billed to Part A are to be charged off as bad debts in the accounting period in which the accounts are deemed to be worthless. In some cases an amount previously written off as a bad debt and allocated to the Medicare program may be recovered in a subsequent accounting period; in such cases this income must be used to reduce the cost of beneficiary services for the period in which the collection is made.

CMS Fraud, Waste and Abuse 1.0

RHC #013

Policy South Central Kansas Rural Health Clinic and each of its affiliates and subsidiaries will comply with the requirements of federal and state laws that prohibit the submission of false claims in connection with federal and state health care programs, including Medicare and Medicaid. Every South Central Kansas Rural Health Clinic employee will receive education and information regarding these regulations.

2.0

Purpose To ensure South Central Kansas Rural Health Clinic is compliant with state and federal false claims regulations.

3.0

Requirements 3.0.1 Federal False Claims Act: a. Prohibits knowingly submitting (or causing to be submitted) to the federal government a false or fraudulent claim for payment or approval. b. Prohibits knowingly making or using (or causing to be made or used) a false record or statement to get a false or fraudulent claim paid or approved by a 59

South Central Kansas Rural Health Clinic state Medicaid program, the federal government or its agents, such as a fiscal intermediary or other claims processor. c. Prohibits making or using (or causing to be made or used) a false statement to conceal, avoid, or decrease an obligation to pay or transmit money or property to the U.S. government. d. This law applies to claims filed by SCKMC/SCK Rural Health Clinic for reimbursement for services provided to beneficiaries under the Medicare or Medicaid programs. e. Civil penalties can be imposed on any person or entity that violates the federal False Claims Act, including monetary penalties of $5,500 to $11,000 as well as damages of up to three times the federal governmentâ&#x20AC;&#x2122;s damages resulting from each false claim.

3.0.2 Federal Fraud Civil Remedies a. The federal Program Fraud Civil Remedies Act of 1986 allows the government to impose civil penalties against any person who makes, presents or submits (or causes to be made, presented or submitted) false, fictitious or fraudulent claims or written statements to designated federal agencies, including the U.S. Department of Health and Human Services. 3.03

Kansas False Claims Act a. Making a false claim, statement, or representation to the Medicaid program is, knowingly and with intent to defraud, engaging in a pattern of making, presenting, submitting, offering or causing to be made, presented, submitted or offered: 1) Any false or fraudulent claim for payment for any goods, service, item, facility, accommodation for which payment may be made, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable;

South Central Kansas Rural Health Clinic 2) Any false or fraudulent statement or representation for use in determining payments which may be made, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable; 3) Any false or fraudulent report or filing which is or may be used in computing or determining a rate of payment for any goods, service, item, facility or accommodation, for which payment may be made, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable. 4) Any false or fraudulent statement or representation made in connection with any report or filing which is or may be used in computing or determining a rate of payment for any goods, service, item facility or accommodation for which payment may be made, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable; 5) Any statement or representation for use by another in obtaining any goods, service, item, facility or accommodation for which payment may be made, in whole or part, under the Medicaid program, knowing the statement or representation to be false, in whole or in part, by commission or omission, whether or not the claim is allowed or allowable; 6) Any claim for payment, for any goods, service, item facility, or accommodation, which is not medically necessary in accordance with professionally recognized parameters or as otherwise required by law, for which payment may be made, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable; or 7) Any wholly or partially false or fraudulent book, record, document, data or instrument, which is required to be kept or which is kept as documentation for any goods, reimbursement of any goods, service, item facility or accommodation for which payment is, has been, or can be sought, in whole or in part, under the Medicaid program, whether or not the claim is allowed or allowable. 8) Any wholly or partially false or fraudulent book, record, document, data or instrument to any properly identified law enforcement officer, any 61

South Central Kansas Rural Health Clinic properly identified employee or authorized representative of the attorney general, or to any properly identified employee or agent of the department of social and rehabilitation services, or its fiscal agent, in connection with any audit or investigation involving any claim for payment or rate of payment for any goods, serviced, item, facility or accommodation payable, in whole or in part, under the Medicaid program. 9) Any false or fraudulent statement or representation made, with the intent to influence any acts or decision of any official, employee or agent of a state or federal agency having regulatory or administrative authority over the Kansas Medicaid program.

b. Making a false claim, statement or representation to the Medicaid program where the aggregate amount of payment illegally claimed is $25,000 or more is a severity level 7, nonperson felony, $1,000 but less than $25,000 is a severity level 9, nonperson felony, less than $1,000 is a class A misdemeanor. 3.0.4 Whistleblower Protections 1) The Federal False Claims Act and Kansas False Claims Act permit private citizens with knowledge of fraud or attempted fraud against the U.S or Kansas State or local government to file suit on behalf of the federal or Kansas government against the person or business that committed or attempted the fraud. If the action is successful, the individual who brought the lawsuit – known as a “qui tam” plaintiff or a “whistleblower” – is entitled to percentage of the amount recovered. The Federal False Claims Act and the Kansas False Claims Act prohibit retaliation against any employee for investigating, filing or participating in a whistleblower action.

Minor Surgrey Policy

RHC #014

1. Policy It is the policy of South Central Kansas Rural Health Clinic to provide safe and quality minor surgical care, assure consistent personnel performance and promote an awareness and understanding of the inherent rights of patients.

South Central Kansas Rural Health Clinic 2. Definition Minor Surgical Procedure â&#x20AC;&#x201C; involves an incision with instruments that can be performed in a brief period of time-usually in less than one hour under local anesthesia, does notunder normal circumstances-constitute a major hazard to life or function of organs or body parts. Minor surgeries do not generally require hospitalization and may be performed electively. Some conditions can be treated by cryosurgery (warts destruction) or simple excision (mole biopsy) which just requires a little local anesthetic and a few minutes. 3. Conditions that can be treated under local anesthesia: a. b. c. d. e. f. g. h. i. j. k. l.

Biopsy of growths; Excision of benign skin nevus; Foreign body removal from skin and soft tissue; Moles; Incision and drainage of an abscess; In-grown toe nails; Laceration and Incision repair of skin and soft tissue; Molluscum warts; Pre-cancerous and cancerous skin lesions; Skin tags/skin biopsy; Skin cyst, abscess; Verruccae warts, etc.

Any other surgical procedure that involves anesthesia or respiratory assistance as a major surgery, we do not perform in our office. 4. Instruments Instruments should be: a. Suitable for the procedure; b. readily accessible during the operation; and c. housed on a surface other than the operating table. A trolley is ideal, but fixed surfaces are equally acceptable. Provisions should be made for the storage of dirty articles pending re-sterilization.

South Central Kansas Rural Health Clinic 5. Clinical Waste Bins Foot operated waste bins with a close fitting lids should be available. Clinical waste bags should be removed at the end of each day and cleaned on a weekly basis. 6. Resuscitation The minimum mandatory requirement of resuscitation equipment should be an adequate airway device and instant access to 1:1000 Adrenaline (epinephrine) 1mg/ml solution. At least one member of staff must be up-to-date with their mandatory completion of CPR training i.e. primary training or annual update with previous 12 months. Establish an emergency call system. 7. Personal Protective Equipment Medical staff carrying out minor surgery should wear disposable water repellant gowns and non-powdered sterile latex gloves. 8. Washing Hands Adequate hand washing facilities must be available close to the room, but not necessarily in it. Surgical hand disinfection must be carried out prior to performing any minor surgery. 9. Exposure Prone Procedures All staff should work within the guidance of the Hepatitis and HIV policy. 10. Recordkeeping The physician must keep a comprehensive record of the procedure undertaken and outcomes.