The College Council recently approved a new policy “Responsibility for a Medical Practice”. This followed a second round of stakeholder consultation, as described in the previous issue of DocTalk. The policy applies broadly to all Saskatchewan physicians who provide patient care in any practice environment except those providing care in facilities owned or operated by the Saskatchewan Health Authority, and facilities designated under The Facility Designation Regulations.
As set out on the CPSS website, policies “contain requirements set by the Council of the College to supplement the Act and Bylaws. Policies are formal positions of the College in relation to defined areas of practice with which members must comply.”
This new policy confirms that physicians are accountable for their own medical practice, including the patient care provided and billing for insured services. In addition, it establishes expectations for physicians in multi-physician clinics (as defined in the policy):
- Each multi-physician clinic must have a physician designated as the “primary contact” for the purposes of communication with the College.
- That primary contact must be able to either answer questions directly or direct the CPSS to another individual within the clinic who can provide the requested information.
- Each clinic can decide on the allocation of responsibilities set out in section 4.4, including:
- Oversight of staff
- Billings for uninsured services
- Advertising and promotion of services
- Quality assurance, quality improvements, and infection prevention and control
- Custody or control of health information
- Providing notification to the College at least 30 days prior to changes in the physical location of the practice or to the services/procedures offered if those require approval by the College pursuant to bylaws
- Ensuring proper identification of all care providers in the clinic.
- Unless another physician in the practice has designated responsibility for the items listed in 4.4, each physician remains individually responsible to ensure these obligations are met.
- Even if another physician in the clinic has designated responsibility for these expectations, physicians retain an individual responsibility to speak up if they are aware of concerns in the function of the clinic/practice environment. If reasonable steps taken by the physician do not result in the appropriate change in the practice environment, physicians must seek guidance from the clinic owner. If the issue remains unresolved, the physician must seek guidance from the Registrar’s Office.
- In some cases, the Registrar’s Office may be able to mediate the situation with the clinic owner by explaining the expectations and encouraging compliance. However, the College has no authority over non-physician owners. In some cases, the College’s advice may be that unless the physician is able to provide proper care to patients in that environment, the physician may need to consider leaving the practice.
The College received more than 135 responses to its second round of consultation, many of which raised legitimate concerns about the proposed requirement (in the previous version of the policy) that all multi-physician clinics must have a physician designated as the medical director. Many respondents expressed that the expectations would place a significant burden on the medical director. Another theme that arose was a concern that a physician designated as the medical director in a clinic owned by non-physicians may result in that physician having the responsibility without the authority to make changes.
All of this feedback was considered by the Council in deciding to remove the requirement for a medical director and instead requiring a “primary contact” for the purposes of communication with the College.
If physicians have questions about the application of this new policy, please contact the Registrar’s Office for assistance.