Legally Speaking
November 2022
By Sheila Torrance, Legal Counsel, CPSS

CPSS Council approves compliance monitoring process related to Medical Practice Coverage policy – is your office ready?

It has now been over a year since the
Medical Practice Coverage policy was amended.  Since that time, the College has taken several opportunities to ensure physicians are aware of their obligations pursuant to the policy:

At its September 2022 meeting, the CPSS Council directed the Registrar’s office to proceed with a compliance monitoring process that will gather data as to the percentage of physician offices that are compliant with the policy.  Details of the process follow:

WHO does this impact:  ALL physicians in Saskatchewan who are involved in direct patient care. As defined in the policy, this includes primary care physicians (including those working at urgent care/walk-in/episodic care clinics/virtual care services), and specialists/consultants providing care as part of a sustained physician/patient relationship.

WHAT:  A compliance monitoring process to determine whether Saskatchewan physician offices are compliant with the Medical Practice Coverage policy

HOW:  Physicians will be randomly selected from within general areas of practice; College staff will call those physicians’ offices a) during the daytime to ensure calls are answered in a timely fashion and/or appropriate messaging is in place, and b) after-hours to ensure appropriate messaging is in place.  As set out in section 3.1 of the policy, messaging must provide clear, accurate and current information on:

  1. a. practice office hours;
  2. b. any office closures;
  3. c. any relevant coverage information (i.e. how the patient can access after-hours, non-emergent care); and
  4. d. instructions on how to access emergency care (i.e. to call 9-1-1).

In addition, messaging must confirm a mechanism is in place to communicate urgent lab or imaging results to the on-call physician or designate, as well as a mechanism for colleagues or associated health professionals to speak to the physician or designate if required.

WHEN:  It is anticipated that this process will start in early 2023.

WHY:  The College continues to receive complaints and concerns from patients and other physicians that they are unable to reach their physician’s office, either due to no one answering the phone during the day, inadequate direction on the voicemail message, or a lack of instructions for after-hours care.  The amended policy clarified the Council’s expectations of physicians; Council now wants to determine whether physicians are compliant, in order to ensure safe and appropriate patient care.  This is an opportunity for physicians to ensure they have appropriate processes and messaging in place.

Council was clear that this will be an educational process at this time.  If physicians are non-compliant, they can expect to receive a telephone call from the Registrar’s staff followed by a letter clarifying expectations that were not met and providing advice on changes to be made to ensure compliance.

  Sheila Torrance is Legal Counsel at the College of Physicians and Surgeons of Saskatchewan.