The Taking of Histories and Physicals by a DPM
Adopted: Wed, 2018-04-18
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It is within the scope of practice for a podiatrist to perform the necessary and complete medical history and physical, including in a hospital setting, a multispecialty ambulatory surgical center and a single-specialty ambulatory surgical center. Prior to practicing as a foot and ankle specialist in these settings, any licensed DPM is required to obtain the necessary privileges from the governing body of the given hospital or surgical center. In turn, it is the responsibility of a hospital or surgical center, when making determinations as to whether to issue or deny privileges, to do so in an unbiased, non-discriminatory manner and based upon the objective factors as set forth by the North Carolina General Statutes.
The opinion that the performance of history and physicals (H&P’s) is within the scope of practice for doctors of podiatric medicine is consistent with the views and rules articulated by both the Centers for Medicare and Medicaid Services (CMS) and The Joint Commission (TJC). Those bodies support the granting of history and physical privileges to podiatrists and also give support to the requirement that the process for granting or denying privileges should be applied equally to all surgeons and not merely based upon the medical degree of the applicant for privileges. In particular, those bodies recognize that foot and ankle surgeons (DPMs) are specialists within podiatric medicine, whose skill and training extends to performing an admission medical history and physical examination leading to the diagnosis, medical and surgical management and treatment of all diseases, deformities, injuries and defects of the foot, ankle and related structures of the leg.
In 2001, The Joint Commission clarified in its hospital accreditation manuals that qualified DPMs are permitted to be credentialed to conduct medical H&Ps. TJC clarified in 2002 and in keeping with the delivery of safe, effective and high-quality healthcare that DPMs could independently conduct their own admission H&P exams, not only in the hospital, but also in hospital-owned ambulatory clinics and related out-patient facilities.
CMS revised its hospital Conditions of Participation (CoPs) to include DPMs as one of the healthcare professionals permitted to perform H&Ps (effective January 26, 2007). The new CoPs provide that “a medical history and physical examination be completed no more than 30 days before or 24 hours after admission for each patient by a physician (as defined in §1861(r) of the Social Security Act), an oral and maxillofacial surgeon, or other qualified individual in accordance with State law and hospital policy. The medical history and physical examination must be placed in the patient’s medical record within 24 hours after admission.” [42 C.F.R. 482.22(c)(5)]. Section 1861(r) of the Social Security Act defines physician to include a doctor of podiatric medicine. [42 USC §1395x(r)(2008)].
The TJC standards specify that the decision to grant, deny or renew privileges should be an objective, evidenced-based process. TJC indicates that evidence of current licensure, current competence, relevant training and ability to perform the privileges requested should form the basis of privilege delineation. The available clinical privileges at an institution should reflect the current state scope of practice and the process should be based on a fair objective analysis, following the same requirements used to evaluate other physician (MD/DO) specialists and with the same due process standards.