Physicians often have a lot of questions about what needs to be done when closing an office/practice. In some cases, there may be particular difficulties involved that demand the physician contact to the CMPA. At other times, a provincial medical college can suffice and provide the appropriate information. Then, of course, there’s always provincial or federal legislation that could provide context or clarity. Whatever the scenario, it is always good to have some general guidelines to the process.
As the digital age brings us into a time of advanced communication and greater mobility, more and more physicians are making the choice to relocate a practice adding to the already myriad “traditional” reasons for closing a practice. Thankfully, the digital age is also providing a lot of new options in dealing with the transition. Below are some guidelines in summary to help you through the closure or transfer of your office and practice.
Alerting Patients, Associates & More
If it is possible to plan notification ahead, there are two things that should be included when notifying.
- Clearly state the date of the closure/transfer
- Clarify the process by which the patient can obtain a copy/transfer of the record
Appropriate formats for notification include:
- a written letter to individual patients
- a posted notice in a general public space at the practice
- an announcement in a local publication
- a voicemail message that will be heard when someone calls into the practice
The Transfer of Records
When patients decide to find another doctor, they will need their medical records transferred to the new practice. It is considered appropriate to charge a service fee for the transfer of medical records, but make sure to check provincial legislation on the matter. The timeframe for the transfer can be between 4 to 8 weeks; anything longer than this is generally considered unprofessional.
Make certain that your office has obtained the correct authorization from your patient before initiating a transfer. Under some scenarios, you might even want to look through the record before transfer. Something to note: a physician’s office should retain the original records, as well as appointment calendars and phone logs. Retaining originals can make a significant difference down the road if a former patient ever initiates a complaint or lawsuit against you. Original records outside your control could be potentially edited, misplaced, or destroyed.
When dealing with record scenarios, make sure that you and your employees keep provincial requirements regarding the retention of records in mind. Even if you maintain digital EMRs, you still need to consider provincial legislation. Whatever your jurisdiction, your law will require that you retain the records responsibly and safely for a certain amount of time. The CMPA considers 10 years a reasonable timeframe for the retention of adult records; for minors, you should retain the record until 10 years after the minor reaches the age of majority.
There are more and more businesses cropping up that can professionally handle EMR or physical record storage. Looking into such options can be very useful, especially when long-term storage is involved.
If you are dissolving a partnership at a group practice, your associates may retain the records; this scenario is naturally more likely if any of your patients are remaining with the practice. You should make sure to have a clearly defined agreement regarding who owns the medical record. It is usually par for the course that the physician who began the record should retain access to it; however, agreements can always help to ensure that no grey areas pop up later on.
PATIENT CARE – Transferring to a New Physician
In some cases, your patients’ care may have been administered under the auspices of a hospital or similar health facility. If that is the case, it is necessary that the medical record contain clear documentation of the patient’s transfer to a new physician.
Setting up follow-up care for those patients who are in the middle of tests is of course critical. It is the moral, professional, and legal duty of a physician to make sure that patients who require follow-up receive it and experience no delay in diagnosis or treatment.
There have been myriad cases of physicians closing their practice and not setting up appropriate follow-up for patients. A good redundancy to put in place to avoid such scenarios is to notify the laboratories, facilities, and referral physicians you work with that you are closing, much as you would your patients and employees. Give them forwarding information and let them know who to get in touch with should a patient fall through the cracks. It is also necessary for a physician to announce their practice’s closure to the body overseeing their medical license and the CMPA.
When closing a practice, ask yourself:
- Have I/we done our due diligence in arranging follow ups for patients who are still in limbo?
- Has timely and clear notice been sent or announced to all appropriate parties?
- Do patients know how and where they can access their medical record?
- Have all transfers involved the correct patient authorization?
- Have long-term arrangements been made for the storage of records?