Alternatives to the hospital emergency room and primary care doctor’s office are opening in strip malls and other retail locations throughout the country. New York State is no exception. In an effort to provide oversight for these walk-in clinics, New York’s Public Health and Health Planning Council (PHHPC) has recommended regulations for these facilities.
The recommendations would place walk-in clinics into one of four categories:
1. Limited Services Clinics (Retail Clinics);
2. Urgent Care;
3. Hospital-Sponsored Freestanding Emergency Departments; and
4. Non-Hospital Surgery- Ambulatory Surgery Centers and Office-Based Surgery.
The recommendations for each category of walk-in clinic are summarized below:
Limited Services Clinics (Retail Clinics)
• The name, marketing materials and all signage would be required to include the term “Limited Services Clinic.”
• Services would be limited to episodic care related to minor ailments and immunizations.
• Surgical, dental, physical rehabilitation, mental health, substance abuse and birth center services would not be permitted.
• No dispensing of controlled substances would be permitted.
• No services could be administered to children 24 months of age or younger.
• No childhood immunizations to patients under 18 years of age (except influenza) would be permitted.
• Accreditation by a national organization approved by the NYS Department of Health (DOH) would be required.
• The clinic would be required to have a Medical Director at the corporate level who is licensed to practice medicine in New York.
Urgent Care Providers
• Urgent Care would be limited to treatment of acute episodic illness or minor traumas.
• Services required would include:
- unscheduled, walk-in visits typically with extended hours on weekends and weekdays;
- Ex-ray and EKG;
- Laceration repair; and
- Crash cart supplies and medications
• The term “Urgent Care” would be required in the name and in all signage at the provider site and in all marketing materials. Other commercial terms could still be used in the provider’s name, but would need to include “Urgent Care” (e.g. “FastMed Urgent Care”).
• The word “Emergency” or its variations would not be permitted for urgent care providers unless licensed by New York State as an emergency department.
• Non-article 28 Urgent Care would require accreditation. No CON review required.
• Article 28 Urgent Care not otherwise accredited would be surveyed by DOH.
• Existing Article 28 Hospital or D&TC providers wanting to provide Urgent Care would require a limited review of their operating certificate.
• Private physician practices affiliated with an Article 28 may provide urgent care if they are accredited or become an Article 28 through CON review.
• Establishment of a new Article 28 Hospital or D&TC to provide urgent care services would require CON review.
Freestanding Emergency Departments
• Hospital-sponsored off-campus “emergency department” would be defined as an emergency department that is hospital-owned and geographically removed from the hospital campus.
• PHHPC recommends that the sponsored off-campus emergency department use the name of the Hospital that owns the facility followed by “Satellite Emergency Department”.
• The facility would be subject to the same standards as a hospital-based emergency department regarding training of providers, staffing, and the array of services provided at the facility.
• Establishment of an off-campus emergency department would require full CON review.
• Accreditation would be required.
• No changes are recommended regarding ambulatory surgery.
• New and existing office-based surgery practices would require registration with DOH.
• All physician practices performing procedures utilizing more than minimal sedation would require accreditation and the provision of adverse event reports.
Limited Services Clinics, Urgent Care providers and Hospital-Sponsored Freestanding Emergency Departments would be required to utilize electronic medical records. Further, these facilities would be required to provide a list of primary care providers to any patient indicating that they do not have a primary care provider. These clinics would also be required to recommend that the patient schedule an initial or annual appointment with a primary care provider and develop policies and procedures to identify and limit repeat encounters with patients.