The following checklist will help sort through some of the issues that a retiring physician may face. It provides reference to a variety of resources that may prove useful with the retirement process.
NOTIFICATION OF LICENSING BOARD: You may obtain a copy of the Reactivation or Status Change Application Physician and Surgeon from the State Board of Medicine. As an alternative to retiring and relinquishing your active license to practice medicine, you may wish to renew your license and request active retired (physicians with an active retired license are excused from maintaining malpractice insurance and meeting CME requirements however, they must pay the biennial renewal fee). Contact the Pennsylvania State Board of Medicine or State Board of Osteopathic Medicine for more information.
RESOURCE:
Pennsylvania State Board of Medicine
P.O. Box 2649, Harrisburg, PA 17105-2649
Phone: (717) 783-1400
Fax: (717) 787-7769
[email protected]
Pennsylvania State Board of Osteopathic Medicine
P.O. Box 2649, Harrisburg, PA 17105-2649
Phone: (717) 783-4858
[email protected]
TERMINATE COLLABORATIVE AND/OR SUPERVISORY AGREEMENTS with CRNPs and/or PAs: Once the collaborative agreement is terminated, CRNPs are responsible for notifying the state Board of Nursing. For supervisory agreements with physician assistants, complete a Written Agreement Change Form and Submit to state Board of Medicine or state Board of Osteopathic Medicine.
RESOURCE:
Practice Guidelines for Physician Assistants and Certified Registered Nurse Practitioners
PATIENT NOTIFICATION: Once a physician-patient relationship is established, a physician has ongoing patient care responsibilities until the relationship ends. It generally is advisable for a notice of retirement or other general unavailability to clearly convey that you will no longer be available to provide care after a designated date but will be available to provide care to the patient prior to the termination date. Urge the patient to obtain a new physician and provide resources or recommendations to help the patient find another area physician. Offer to provide a copy of the patient’s medical record to the patient or transfer a copy to the patient’s new physician, and explain any applicable copying and mailing charges. Identify who will be maintaining custody of the medical record (so that the patient can access in the future). It is generally best to provide the notice in writing either face-to-face or via mail and to place a notice in the local newspaper(s). Generally speaking, 30 days prior notice is the norm for notice however, it is usually best to err on the side of providing too much notice, especially in the case of a planned retirement when longer notice is feasible.
EMPLOYEE NOTIFICATION: The time and manner of notifying employees of your intent to retire is an individual consideration that will vary from practice to practice and may depend upon the employment contracts you have with your employees. Review existing employment contracts (or have them reviewed by an attorney) to ensure that you are meeting all of your contractual obligations.
MALPRACTICE INSURER NOTIFICATION: It is possible that after you retire you may be sued for malpractice arising from treatment rendered while you were still in practice. In the event you have claims-made malpractice coverage, (as opposed to occurrence-based coverage) you may need to purchase additional “tail” coverage to ensure that you and your practice will be covered in the event a medical malpractice claim is filed against you in the future.
HEALTH PLAN NOTIFICATION – MEDICARE, MEDICAID AND/OR COMMERCIAL INSURERS: Medicare requires physicians to deactivate their Medicare billing number. You can accomplish this with the Centers for Medicare and Medicaid (CMS) Form 855I. The instructions for the CMS-855I specify the sections you will be required to submit. The Pennsylvania Department of Human Services and other commercial plans for which you participate should also be notified at least 30 days prior to the date of your retirement. Physicians should follow the health plan’s protocol for terminating their participation with the plan. Your provider agreement/contract should explain how to withdraw from the agreement and the required advance notice to withdraw. Physicians in accordance with their provider contracts should submit letter of notification (on your letterhead) to include name, address, phone number, provider number and/or Tax ID number, date of retirement and original signature.
RESOURCE:
CMS Form 855I – https://www.cms.gov/cmsforms/downloads/cms855i.pdf
RETENTION OF MEDICAL RECORDS: A patient’s medical record shall be retained for at least 7 years from the last medical service for which a medical record entry is required. The medical record for a minor patient must be retained for at least 7 years or 1 year after the patient turns 18, whichever is longer. The State Board of Osteopathic Medicine regulation sets an identical standard for osteopathic physicians, except that the extended period for minors is two years after the patient turns 18. In the event you have medical records that were created by another physician, you should retain those records in the same manner that you would retain the records you created. You may satisfy the Board’s record retention requirements by entering into a written agreement with a successor physician or medical records management company whereby the other party is required to maintain your records in accordance with all federal and state requirements with which you must comply. Such written agreement should permit you access to the medical records for a reasonable period of time following the transfer. You may wish to consult legal counsel about this issue.
RETENTION OF BUSINESS RECORDS: Business records must be retained after you retire. You may wish to consult an attorney to help you determine how long you should retain business records including but not limited to, payroll records, personnel files, accounts payable, invoices, credits, contracts, billing records and OSHA. The HIPAA privacy regulations require physicians to retain HIPAA documentation (e.g. acknowledgement of receipt of privacy notice, requests for amendments and workforce training documentation) for a period of at least six years.
DEA Notification: Physicians must notify the DEA to request their registration number be deleted from the system in the event they do not intend to continue to write prescriptions. If you so choose, you may notify the DEA by telephone, mail or making a notation of “non-renewal” due to retirement” on your DEA renewal form.
RESOURCE:
United States Drug Enforcement Administration
William J. Green Federal Building
600 Arch Street, Room 10224
Philadelphia, PA 19106
Eastern Pennsylvania and Delaware – (888) 393-8231, Fax – (215) 238-2480
Western Pennsylvania (zip codes 150-168) (412) 777-1870 or Fax (412) 777-1880
Notify hospitals and/or nursing homes
Notify Professional Associations
Notify landlord, vendors and utility companies
Close medical practice bank accounts and credit cards
Change mailing address
Cancel subscriptions
Contact the Social Security Office if 62 or older: Learn more about obtaining social security benefits.
Resource: http://www.ssa.gov/ or 1-800-772-1213
The checklist as outlined is intended to provide general information for the retiring physician.
