Moving a Medical Practice: A Checklist

Name one owner for the move, usually the practice administrator, and keep one master schedule. Tie it to the dates in both leases: rent start and delivery at the new site, and surrender and holdover at the old one. Find out which approvals have to be in hand before you may see patients or use equipment at the new site. Those dates drive everything else.

1. Confirm lease dates, including any holdover rent, restoration work and required notices.
2. Build a list of every license, registration, payer contract and vendor tied to your address.
3. Ask your attorney and state licensing agency what applies to your specialty and state.
4. Set a date for clinic closure and reopening, and reduce the schedule around it.
5. Decide what moves, what is replaced and what is retired, including anything that needs a vendor to disconnect or reinstall it.
6. Send notices in the order and on the schedule set out below.
7. Walk the new space with clinical staff before the first patient arrives.
8. Close out the old space and keep proof of surrender.

TAG's role centers on the lease and the space, so ask your advisor to hand this schedule the dates and surrender terms from both leases at the start.

Your liability carrier may have a relocation procedure and sample letters. Ask for it. The Doctors Company's guidance on closing or relocating a practice offers a useful model, and these items draw on it. Its guidance tells readers to consult their attorney and state licensing agency for requirements specific to their situation.

• ✓Have we identified active patients, including those in an acute phase of treatment?
• ✓Has a letter gone out by first-class mail with the new address, phone and move date, with a copy kept in each patient's record?
• ✓Should high-risk or acute patients get a certified letter or a direct call?
• ✓Have we updated our website, portal, voicemail, social accounts and online listings?
• ✓Do staff have a short script for questions about the move?
• ✓Have we told referring physicians, hospitals and affiliated practices?
• ✓Have we given patients an easy way to ask for a copy of their records?
• ✓Have we posted our HIPAA Notice of Privacy Practices at the new site?

That last item comes from 45 CFR 164.520, which says a provider with a physical service delivery site must have the notice available and post it in a clear and prominent location. Ask your privacy officer whether your notice needs revising because of the move.

State rules on how and when to notify patients vary, so check them. The Doctors Company suggests that closure notices go out at least 60 days in advance. That figure is for closing a practice, so treat it as a reference point for planning, not as a relocation rule.

Some of these filings have firm deadlines. The items below come from the regulations cited. Rules can change, so confirm each with the agency or your counsel.

• Medicare. Under 42 CFR 424.516(d), physicians, nonphysician practitioners and their organizations must report a change, addition or deletion of a practice location to their Medicare contractor within 30 days. Other provider types have their own rules.
• National Provider Identifier. Under 45 CFR 162.410, a covered health care provider communicates changes in its required data elements to the National Provider System within 30 days of the change.
• DEA. Under 21 CFR 1301.51, a registrant may apply to modify its registration to change its name or address by written request or online. Ask counsel when to file so that the new location is covered before controlled substances are moved or handled there.
• Clinical laboratory. Under 42 CFR 493.51, laboratories with a CLIA certificate of compliance must notify HHS or its designee within 30 days of a change in location. Other certificate types have their own sections, so confirm which applies.

A federal deadline can run from the change itself, while a payer or licensing body may want notice well before it. Build the schedule around the earliest date, not the last one allowed.

This list varies more than any other part of the move. Treat it as a prompt for your own inventory.

• ✓Do our state medical board and other professional boards require an address update, and by when?
• ✓Does our state need a new facility license, inspection or registration for procedures, imaging, lab or dispensing?
• ✓Do we need state registration for x-ray equipment at the new address? Illinois, for example, requires x-ray equipment to be registered with the state agency under 32 Ill. Adm. Code 360.30.
• ✓Do we need new shielding approval? Michigan, for example, says re-approval should normally be obtained when equipment is replaced or major room renovations are made.
• ✓Has Medicaid been notified, along with each commercial payer and network? The Doctors Company suggests written notice to payers by certified mail and a review of participation agreements.
• ✓Have hospital medical staff offices been told, and do privileges or call coverage depend on location?
• ✓Have our malpractice, property, workers' compensation and business insurers been told about the new address?
• ✓Have we arranged local permits, business licenses and signage approvals?
• ✓Have we set up a medical waste vendor for the new site? EPA says medical waste is regulated primarily by state agencies.

Keep a running log showing each party, the date notified and the date confirmed. Claims that fail because a payer has the old address are expensive to fix after the fact, so ask each payer how long its update takes.

Clinical equipment and patient records need more care than furniture. Ask each vendor about disconnection, moving, reinstallation, calibration and service contracts. Ask whether moving a machine affects its warranty, and which equipment needs testing before clinical use. Medications and vaccines need a temperature-control plan, and controlled substances need a plan cleared with counsel.

For records, the HIPAA Security Rule at 45 CFR 164.310(d) addresses movement of hardware and electronic media. It includes a required specification for final disposal and media re-use, and an addressable specification for keeping a record of movements. HHS has said covered entities may not simply abandon protected health information or put it in dumpsters or other containers accessible to the public. Have your IT lead back up data before the move, and ask any moving or storage company about a business associate agreement. Medical Mutual, a physician liability insurer, recommends a business associate agreement with a storage firm or a destruction service. Check your state's retention rules before purging anything.

Your lease decides what surrender means. Walk the space with the lease's surrender and restoration clauses in hand, and get the landlord's confirmation in writing.

• ✓Have all records, devices, sharps containers and medications been removed?
• ✓Does the lease require us to remove cabling, shielding or other improvements?
• ✓Have we given the required notice and arranged a final walk-through?
• ✓Have we returned keys and access cards, and taken dated photos?
• ✓Do we have a date for the return of our security deposit?
• ✓Have we arranged to forward mail, phones and messages after the move?