September 9, 2010 Leave a comment Go to comments

This story, via WhiteCoat, deals with a hospital in Tennessee that is slated to lose Medicare payments because of violations of the participation agreement between the hospital and the Centers for Medicare/Medicaid Services (CMS).  What violations, specifically?

That staff member did not follow the procedures for handing this type of problem that are spelled out in the company’s organizational policy manual or its employee handbook, said Pat Kane, Wellmont’s vice president for communications and marketing.

Normally, it would have been considered a simple personnel issue, Kane said, except the Centers for Medicare investigation found that only 88 percent of the hospital’s 1,500 employees have read the entire policy manual.

“We got dinged for that,” Kane said after Monday’s news conference. “They just hadn’t gone all the way through [the policy manual] and they should have.”

During its investigation, the agency also found some expired medical supplies on the hospital’s shelves and identified a personnel policy that treated the hospital’s medical staff differently than the rest of its employees, Sargent said.

Let’s recap.  If this story is to be taken at face value, the issue is not that a Medicare patient was mistreated at the hands of hospital employees.  The issue is not that a hospital employee did not follow the hospital’s internal policy for dealing with belligerent patients.

What has prompted the lumbering behemoth that is CMS to unleash its full fury, backed by the might and power of the federal government and the Righteousness Of Contract Enforcement… is that 12% of this hospital’s employees have not read the entirety of the institution’s policy manual.  Oh, and the personnel rules governing independent contractors (i.e. the medical staff at many if not most hospitals) are different from those governing actual employees.

I believe this is what Dr. Rich would call a “regulatory speed trap.”

If the journalist isn’t missing anything important, this means that there probably isn’t a single hospital in America that qualifies for Medicare participation based on the letter of the law, such that CMS officials would seem to have near-unlimited discretion in choosing hospitals to mess around with, should they so choose.

Let’s be honest… even of all those people who have “read” the full manual at their hospital, how many can say they remember and understand all of it?  For that matter, academic medical centres must have even worse compliance, what with all the medical students involved with care who probably aren’t even aware of half of these policy manuals……….

Erm.  Right.

If you’ll excuse me, I think I have some reading to do.


For those confused by the title, “RTFM” is an acronym used by some of the geekier members of my demographic.  It stands for “Read The [Finely-written] Manual.”

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