Managed Care

Psychiatrist and RN continuity of care relationship

  • 1.  Psychiatrist and RN continuity of care relationship

    Posted 01-20-2016 03:22 PM

    I am totally stumped for an answer to the following questions that our Medical Director recently asked me:

    Scenario: We have a contract, using CA Mental Health Services Act (MHSA) funding, with a healthcare provider to provide Mental Health Services to Transitional Age Youth (16-25). They, in-turn, have subcontracted the psychiatry services to an individual provider who also happens to contract with our Youth & Family Services program on a part-time basis. The sub-contracted provider prescribes injectables for the TAY client, but the contractor does not have a nurse to administer the injection.

    Questions: Would it be appropriate for the psychiatrist to prescribe the injection and it be administered by our RN? If so, should both the psychiatrist and the RN need to chart in the YFS (our) EHR? Some of this may be claimed to Medi-Cal (Medicaid).

    Any and all thoughts/comments would be most welcome and appreciated.

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    David Rothery, CHC
    HIPAA Privacy Officer
    CA
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    2019 HCCA Compliance Institute


  • 2.  RE: Psychiatrist and RN continuity of care relationship

    Posted 01-21-2016 12:00 PM

    The description you provide appears to reflect that the providers are providing treatment to the patient on behalf and at the premises of the organization, whether contracted or employed and therefore,  the RN is able to administer a prescription written by the treating psychiatrist.  If the psychiatrist is treating the patient at another location, that is completely different and in that case, I suggest tracking how the drug is managed from place to place and whether or not it could be managed as a patient's drug brought to the RN for administration. 

    As usual with all services, documenting comprehensively all that takes place with each provider for multiple reasons, including supporting the billing of an ordered prescription and the administration, then setting the stage for the on-going med management monitoring visits that will most likely be associated.

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    Martina Manzone, CHC CCEP
    President
    Maatangi Analytics, Inc.
    Madison,TN

    2019 HCCA Compliance Institute