Scope of Service
By: April McLain
I have been a nurse in healthcare for nearly 40 years and have spent much of my career directly or indirectly responsible for regulatory compliance. Many of the standards and regulations promulgated by CMS and accrediting bodies’ standards have been in place for many of those years. I forget at times, that while a regulation or standard has been around nearly as long as I have, there are others just getting started in regulatory compliance, therefore, a brief refresher of an old topic may be helpful. One such topic is scope of services.
What is a scope of services? Simply put, a scope of services is the services provided to patients within the capability of the organization to meet the healthcare needs of the patient. Not every healthcare organization has the capability or capacity to provide all healthcare needs of patients, and having a defined scope of services provides guidance. In the case of a critical access hospital, CMS will specifically review the organization’s scope of services to verify the organization has the facilities and resources to support the services provided.
The standards for the scope of practice are not prescriptive. In broad terms, the organization’s scope of services can be as simple as a list of services provided either directly or contractually by the organization; and a separate list of services not provided by the organization. If services are not provided at the organization, the organization will need to develop agreements with other organizations or providers that provide the service. The scope of services can be contained in a policy and approved by the governing body. While CMS does not specifically require governing body approval, it is implied as the governing body is ultimately responsible for the activities of the organization. Other accrediting organizations may have more specific standards that require evidence that the governing body has approved the organization’s scope of services.
Regardless of how the organization chooses to document their broad scope of services, all services are required to be integrated into the organization. Examples of integration include:
From the broad scope of services, departmental scope of services can be developed. This is where the specific details of the care and services provided to patients are documented. The details of a departmental scope of service should contain the following:
In lieu of a single broad organizational scope of services policy, many organizations combine the individual departmental scope of services into a single document that is then approved by the governing body. It is left up to the organization to determine how its scope of services will be documented.
CMS Conditions of Participation for Acute Care Hospitals does include specific requirements for written descriptions of the scope of services for certain services as listed below:
A final word on scope of services. There are no specific requirements by CMS as to the frequency of review of the organization’s scope of services. Anyone in healthcare knows that services change, some are added, some are deleted, and some are modified. Making sure your scope of services document keeps up with the changes can be a challenge. Placing your scope of services on a regular review schedule will help keep it current and in good standing with CMS and your accrediting organization.