decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Special Advisory Bulletins / OIG-CMS Special Advisory Bulletin 99-3_Nov 10, 1999 / Managed Care Plans and 'Dual Staffing'
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Article Overview
This article explains federal guidance on managed care organizations and hospitals that use dual staffing in emergency departments. It focuses on why the arrangement matters, the agencies involved, and the general compliance concerns tied to emergency screening, stabilization, transfers, oversight, and patient protections. The bulletin is relevant to hospitals, emergency departments, managed care plans, compliance teams, and health care administrators reviewing emergency care operations.
Why This Topic Matters
The bulletin addresses a delivery model that can affect how emergency care is organized and monitored in hospital settings. It is important for organizations evaluating whether staffing arrangements may create access, timing, or oversight concerns under federal requirements.
Article Sections
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Overview of dual staffing arrangements
Introduces the emergency department staffing model discussed in the bulletin and the organizations and settings involved.
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Federal requirements and patient protections
Summarizes the broader federal framework referenced in the bulletin, including emergency care obligations and related protections.
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Arguments for and against dual staffing
Describes differing views in the health care community about the operational effects of dual staffing in emergency departments.
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Operational concerns and potential problem areas
Outlines the types of workflow, oversight, and transfer issues discussed for dually staffed emergency departments.
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Overall compliance perspective
Explains the bulletin’s general position on whether the staffing model is automatically prohibited and the need for continued compliance review.
What You Will Learn
- The federal emergency care framework referenced in the bulletin
- How dual staffing is described in managed care and hospital settings
- The general categories of compliance concerns raised by this staffing model
- Which types of operational differences may draw regulatory attention
- Why hospital policies and oversight processes matter in dually staffed emergency departments
Who Should Read This
- Hospital compliance staff
- Emergency department administrators
- Managed care organization leaders
- Health care attorneys
- Revenue cycle and patient access teams
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