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CMS Revises Interpretative Guidelines for Rehabilitation in Outpatient Hospitals

In response to concerns raised by the American Physical Therapy Association (APTA) and other associations, the Centers for Medicare and Medicaid Services (CMS) has revised interpretative guidelines (Transmittal 72) to eliminate the requirement that rehabilitation services furnished in outpatient hospital settings be ordered by a practitioner with medical staff privileges.

The new guidance issued to the State Survey Agency Directors on February 17, 2012 is effective immediately and includes the following language:

Requirements for Ordering Hospital Outpatient Services: Outpatient services in hospitals may be ordered (and patients may be referred for hospital outpatient services) by a practitioner who is:
• Responsible for the care of the patient;
• Licensed in, or holds a license recognized in the jurisdiction where he/she sees the patient;
• Acting within his/her scope of practice under State law; and
• Authorized by the medical staff to order the applicable outpatient services under a written hospital policy that is approved by the governing body. This includes both practitioners who are on the hospital medical staff and who hold medical staff privileges that include ordering the services, as well as other practitioners who are not on the hospital medical staff, but who satisfy the hospital’s policies for ordering applicable outpatient services and for referring patients for hospital outpatient services.


For more information about outpatient hospital services, please contact Abby Pendleton, Adrienne Dresevic, or Jessica Gustafson at (248) 996-2510 or visit The HLP website.

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