If you will be providing the notification personally, consider sending letters by certified mail to any higher risk patients who may be significantly affected by the change and notification to all active patients by regular mail. If you include an authorization for the release of medical records, it can expedite the process for record transfer either to your new practice or to any other provider that the patient may see in the future. Again, your employment or separation agreement may dictate the manner of providing notification to patients and should be reviewed carefully.
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States have different requirements regarding the length of time that medical records are retained, and some HMO or managed care agreements also include retention requirements. You will want to include who will maintain the records, as well as how you will obtain access, if needed.
The physician practice may have to notify third parties pursuant to certain contractual notice requirements, including managed care contracts. You should also make sure the medical staff committee of any hospitals where you have privileges and the state medical board are notified. If you are a provider enrolled in Medicare, you will need to notify the Centers for Medicare and Medicaid Services (CMS) of any information that changes your provider agreement.
Taking these considerations into account should make your transition to new opportunities go more smoothly.
Steven M. Harris, Esq., is a nationally recognized healthcare attorney and a member of the law firm McDonald Hopkins LLC. Contact him via e-mail at [email protected].