QUESTION:        A physician on staff is asking to bring his office manager to the hospital to “assist” him when he rounds.  We presume that means the individual will be serving as a scribe, but aren’t really sure.  Should he or she be allowed to accompany the doctor?  If so, should we try to limit the scope of activities he or she can engage in?

ANSWER:            Many organizations are struggling with the issue of physicians wanting to bring office employees with them to the hospital to do certain tasks. Sometimes this includes private scrub personnel.  The body of issues raised will generally depend upon the role that the physician intends for the office personnel to fulfill.

It is appropriate to define threshold qualifications, in terms of education and training, that a physician’s employee or contracted staff would be required to meet to be eligible to apply as an allied health professional.  Private scrubs, for example, could be limited to registered nurses, operating room or surgical technicians, or licensed practical nurses who have been properly trained.  If a physician’s employee does not possess these qualifications, he or she would not be eligible to apply.

With respect to other office personnel who might accompany the physician as a “scribe,” the hospital could require that the physician be physically present with such personnel at all times.  Whether such personnel should be permitted to make entries in records in the presence of the physician is up to the hospital.  Certainly, the physician would have to remain personally responsible for all record entries.

The bottom line is that the hospital has the responsibility and the right to define specifically what physician-directed personnel can and cannot do in the hospital and that the individual should be appropriately authorized before providing any level of treatment or service.  If the individual is an advanced practice registered nurse (i.e., an NP, CNM, CRNA) or a physician assistant, he or she must be credentialed and privileged through the medical staff process per both CMS and accreditation standards. For truly dependent practitioners who do not provide a medical level of care, there is more flexibility.  Some organizations have chosen to handle such personnel through the human resources department, when medical staff office resources are constrained.