A member recently contacted ECRI Institute seeking guidance for developing a policy and procedure to ensure continuity of care when a provider leaves the health center.
In our response we provided starting points for a policy about notifying patients of a provider's departure. Because the content of the notice will depend on state law, ECRI Institute recommends that facilities consult legal counsel to review applicable state laws.
For example, the Ohio Medical Board has adopted specific rules about the content of the notice, which must include the following (rule 4731-27-03):
- Notice to the patient that the physician will no longer be practicing medicine at the healthcare entity
- The date the physician ceased or will cease to provide medicine services at the healthcare entity
- If the physician will be practicing medicine in another location, how to contact the physician after he or she has left the healthcare entity
- Contact information for an alternative physician or physicians employed by the healthcare entity or contact information for a group practice that can provide care for the patient
- Contact information that enables the patient to obtain information on his or her medical records
The Ohio rules require the healthcare entity to send the notice to patients, but the organization may satisfy its statutory obligation by providing patient contact information to the departing physician and requiring the physician to send the notice to patients.
The Medical Board of California advises that patients should be notified of changes in the medical practice and recommends that "due care should be exercised when closing or departing from a medical practice." California healthcare entities should review guidance from the California Medical Association before sending the notice.
In addition, the American Medical Association's ethical opinion 3.3.1 states that to fulfill his or her "ethical obligation to manage medical records appropriately," a physician must "[provide] copies or [transfer] records to a third party as requested by the patient or the patient's authorized representative when the physician leaves a practice, sells his or her practice, retires, or dies."
To ensure continuity of care, staff should be given a copy of the written notice so that they can discuss it as needed with patients who may call the practice. Ensure all medical records are complete (specify a time frame prior to the provider's departure). Provide options for patients looking to schedule appointments.
Office practices should also consult their information technology (IT) vendor to see how best to set up group coverage or delegates to receive incoming messages directed to the provider who has left and to handle outstanding orders, test results, and medication refills. Multiple people should share this responsibility to ensure proper coverage. Also, ensure IT terminates the departing provider's computer access timely.
Off-boarding checklists available from the Department of Pediatrics at the University of Utah Health and from Washington Association Medical Staff Services include more elements that could be considered in a policy.
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The recommendations contained in Ask ECRI do not constitute legal advice. Facilities should consult legal counsel for specific guidance and develop clinical guidance in consultation with their clinical staff.