Question: We have several “office-based” providers on our Medical Staff who do not have inpatient privileges.  The hospital employs these physicians and owns the clinics where they practice.  These physicians are granted office-based privileges by the hospital.  They would like to be able to order blood transfusions and IV antibiotics in our Infusion Center.  Are they permitted to do this?

Answer: If the Infusion Center is an inpatient service, then the “office-based” providers would have to have inpatient clinical privileges to order blood transfusions and IV antibiotics.  In a recent CMS memorandum on orders for outpatient services by practitioners without clinical privileges, CMS indicated: “It was not our intention to create access to care barriers or to limit the ability of practitioners who are appropriately licensed, acting within their scope of practice, and authorized under hospital policies to refer patients for outpatient services. We distinguish these outpatient referral cases from cases where a practitioner provides care in the hospital, either to inpatients or outpatients, and must have medical staff privileges to do so.” (emphasis added).  However, if the Infusion Center is an outpatient clinic, then the office-based providers could order these services, according to a hospital policy that complies with the criteria in that CMS memo.