SNF referral to outpatient practice

[pinstriped1992]

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Does anyone have experience with referring patients from a SNF to your own outpatient practice? I'm 1099 for both sides, but I'm not sure is this is standard practice or can this skew into Stark violation? I don't have any kick-back from either side other than continuity with SNF patients and I don't plan to offer any incentive to patients to follow with me other than that I'm their closest PM&R provider that accepts their insurance.

 

[RangerBob]

I see specialists recommend output follow up all the time for the patients I see on acute rehab.

Are you primary or the consultant? If you’re a consultant, just request the primary arrange output follow up with you and you’re no different than the specialists above.

I’m guessing even if you’re primary it’s not a Stark violation since it’s a follow up with yourself. But I don’t know this for certain and others with relevant experience/expertise can chime in

 

[pinstriped1992]

Are you primary or the consultant? If you’re a consultant, just request the primary arrange output follow up with you and you’re no different than the specialists above.

I’m guessing even if you’re primary it’s not a Stark violation since it’s a follow up with yourself. But I don’t know this for certain and others with relevant experience/expertise can chime in

I suppose that is another way to distance from Stark Law issues by having another person signing to the referral orders. I would be the consultant not primary.

 

[Momentum70]

I know if you are the primary that its not a stark law violation. So for instance if you see them as primary at IRF then you can decided to follow up. I dont work at snf but if you are a consultant then may be best to have primary refer. Our group does consults for acute with recommendations for follow up like home health/snf/irf. If they go irf then typically will come to us. We cant make that referral though. We only make the recommendation in our note and then the primary team puts in referral.

 

[pinstriped1992]

I know if you are the primary that its not a stark law violation. So for instance if you see them as primary at IRF then you can decided to follow up. I dont work at snf but if you are a consultant then may be best to have primary refer. Our group does consults for acute with recommendations for follow up like home health/snf/irf. If they go irf then typically will come to us. We cant make that referral though. We only make the recommendation in our note and then the primary team puts in referral.

Yes I wouldn't place orders, this would all be the discretion of the primary to make recommendations and consider follow up options/place order