Mental health professionals are too often pressured by time
and money constraints to do what they consider a thorough
job.
The American Academy of Child
Psychiatry in 1997 appointed a Task Force on
Psychiatrists' Signatures, chaired by Dr. Alan Axelson, which
offered recommendations on what a psychiatrist's signature
should mean, and when it should be given.
Also on this page are guidelines on the prescribing of
medicine for children.
We provide these excerpts so you can have knowledge to be a
better parent and consumer of mental health services for your
child.
Task Force on Psychiatrists' Signatures
Policy Statement
The Assembly was mindful of the often erratically changing
practice climate of the last several years, and of the strains
that these changing conditions place on psychiatrists'
ability to practice in the best interests of patients and in
professionally sound ways. Previously unforeseen clinical,
financial and administrative relationships among and between
psychiatrists, patients, and administrative and business entities
have developed, and continue to evolve in a dizzying way.
1.0 General Principles
In signing a document, a psychiatrist assumes a number of
legal and ethical responsibilities associated with that document.
Signing documents therefore, should be done thoughtfully and in
accordance with legal and ethical principles.
1.1.0 Role Implications
Unless otherwise specified, the signature of a psychiatrist on
a clinical document implies that he or she has prepared the
document personally, has had personal contact with the patient,
and takes responsibility for the content of the document.
Psychiatrists may endorse documents ethically in other
situations, for example, when they are functioning in adjunct
roles. Appropriate other roles may include administrative or
clinical supervisor; treatment team member and collaborating
psychiatrist or consultant (Appelbaum, 1991). The
psychiatrist's role should be explained either in the body of
the document or near the signature. When the psychiatrist is
providing supervision, the supervisee's name and role should
also appear in the document (California Psychiatric Association,
1995a, 1995b). The same procedures should be followed in
collaborating relationships.
1.2.0 Use of Colleagues' Names
A colleague's name on a document may imply co-authorship
or shared responsibility for the document. This principle may
apply to the use of colleagues' names in a description of an
informal consultation concerning a patient's treatment.
Colleagues' names, therefore, should be included in documents
only with their permission.
1.3.0 Use of Dates
A date is a component of the authentication of a document. A
date near a signature ordinarily indicates when the document was
signed. If the document is a summary of an evaluation performed
on another date, a statement should be made to that effect.
The date on a prescription order must coincide with the date
the order was written. It is fraudulent and unethical to
post-date or otherwise incorrectly date a prescription, and those
doing so may be subject to prosecution by the Drug Enforcement
Agency. For Schedule II substances, including stimulants, it is
also unlawful to include a refill order in a prescription.
1.4.0 on-Call Responsibilities
Physicians frequently provide coverage for medical colleagues
who are not available. The on-call coverage relationship should
be pre-established in an oral or written formal agreement.
Afterward, it is appropriate for a covering psychiatrist to use
his or her signature or telephone authorization to manage
treatment prescribed by the patient's psychiatrist.
2.1.0 Disability Documents
A psychiatrist's signature on a document to determine
eligibility for disability or other benefits indicates that the
psychiatrist has objectively assessed the medical condition of
the patient, and has not based the determination solely on a
patient's request, a family need, or other social
factors.
2.2.0 Forensics Documents
In forensic evaluations, such as those to determine custody or
responsibility for criminal behavior, the psychiatrist's
signature indicates that he or she has evaluated the patient and
accurately answered the questions asked. The psychiatrist's
role as an agent of the court should be indicated in the document
so that this role is not confused with the usual
psychiatrist-patient relationship.
2.3.0 Treatment Plans
The signature of a psychiatrist on a treatment plan does not
necessarily signify that he or she has examined the patient, but
it does indicate that the psychiatrist has reviewed written or
verbal clinical material sufficient to support the diagnosis and
treatment plan. A psychiatrist may sign a treatment plan in this
manner as part of his or her role as attending psychiatrist,
treatment team leader, treatment team member, supervisor, or
consultant. The role should be indicated with the signature or in
appropriate administrative policies (American Psychiatric
Association, 1989).
Although a treatment plan may be based on the assessment of
others, by signing, the psychiatrist accepts responsibility for
the treatment plan consistent with his or her specified role.
Therefore, psychiatrists should allow for sufficient time for the
review and completion of documentation before signing a treatment
plan.
2.4.0 Administrative Reviews
Signatures on documents related to quality assurance review,
or other administrative review of clinical records indicate that
the psychiatrist has executed his or her responsibility as
established by the guidelines of the facility. By signing a
quality assurance or review document, the psychiatrist is
indicating that to the best of his or her knowledge, the
guidelines under which he or she is working comply with
professional, ethical, and legal standards. When involved in
administrative or quality review, therefore, psychiatrists assume
considerable responsibility for the quality of the treatment
process. The nature of the psychiatrist's involvement should
be indicated in the document or in appropriate administrative
policies.
2.5.0 Prescriptions for Medications
A psychiatrist's signature on a prescription is a
statement that he or she has seen and evaluated a patient and
selected an appropriate medication. An accurate evaluation can be
made only when the psychiatrist has spent sufficient time in
clinical interviews and evaluation of collateral information or
diagnostic testing. Signatures on subsequent prescriptions imply
that the psychiatrist is reevaluating the patient's
continuing need for the medication at intervals consistent with
the patient's condition.
When the prescription is written for a patient who is
receiving psychotherapy from a non-physician therapist, the
prescribing psychiatrist risks being held legally responsible for
not only the medication management but also the treatment being
provided by the non-physician therapist.
2.5.1 Prescription Privilege
The prescription of psychotropic medications for the treatment
of complex psychiatric illnesses is an intervention to be made
only by an appropriately trained psychiatrist. In no case should
a psychiatrist prescribe medications
Solely at the direction of a non-psychiatrist, which would
enable another clinician to assume a role outside the scope of
his or her license.
Signing blank prescriptions is unethical and illegal. There
may be situations, such as medication monitoring of a stable
patient, where nurse practitioners or physician assistants,
operating within their scope of practice, may prescribe under the
supervision of psychiatrists.
Psychiatrists in the role of "physician" may use
their signatures to support the prescribing activities of
resident physicians practicing under a limited license.
2.5.2 Telephone Transmissions of Prescriptions
Telephone contact or facsimile transmission to a pharmacist by
a psychiatrist may be substituted for a signed prescription.
Delegation of a verbal order for a prescription, however, should
be made only to registered nurses or other professionals who are
licensed to accept it. In certain jurisdictions a telephone or
fax prescription may require authentication with an original
signature.
2.6.0 Billing Documents
Psychiatrists' signatures commonly authorize insurance or
other billing documents. The psychiatrist's signature
indicates responsibility for the integrity of the billing
information, including accurate identification of the treatment
provider and the nature of the treatment provided (American
Psychiatric Association, 1991).
It is illegal and unethical to submit a bill or to have a bill
submitted on a psychiatrist's behalf for treatment not
provided by that individual. If the bill is for treatment
provided by a professional working under a psychiatrist's
supervision, the relationship must be specified and the treating
professional's degree identified on the bill.
The psychiatrist is responsible for the uses of his or her
name and signature on billing documents prepared by
administrative support staff. This includes the uses of the
psychiatrist's signature stamp. Psychiatrists must be certain
that the procedures followed by support staff are ethical, legal,
and accurate to the payer's requirements.
2.7.0 Treatment Authorizations
When psychiatrists, by signature or name, request treatment
authorization from a managed care company or other agent, an
accurate description of the patient's condition and treatment
needs should be provided. Using an incorrect diagnosis to gain
insurance coverage, or misrepresenting treatment modalities in
order to gain authorization is unethical, even when motivated by
concern for patients. This principle reflects the Code of Ethics,
Principle XVII (American Academy of Child & Adolescent
Psychiatry, 1980).
2.8.0 Authorization Reviews
When a psychiatrist, as the agent of a managed care
organization, makes a determination regarding the authorization
of treatment, his or her signature indicates that he or she has
made a medical judgment determining that the treatment meets or
does not meet the utilization criteria of the organization.
Furthermore, the psychiatrist's signature affirms by
implication that the utilization criteria being followed comply
with professional, ethical, and legal standards, and that the
psychiatrist subscribes to these criteria. This principle applies
even when the documents are intended strictly for internal use in
the organization.
3.0 Managed Care Contracts
The psychiatrist's signature on a contract with a managed
care company or provider network indicates that he or she agrees
to abide by the terms of the contract. Reservations regarding
terms of the contract should be negotiated, and the contract
revised, before signing. Minor disagreements with parts of a
contract can be addressed by crossing out offensive clauses or
including substitute language, then initialing and dating the
area.
4.0 Conclusion
By signing a document, a psychiatrist indicates that he or she
understands and is willing to assume a number of important
responsibilities associated with that document. The assumption of
these responsibilities is part of the value of the services
provided by psychiatrists. Psychiatrists must use care,
discretion, and integrity when signing documents, to minimize
vulnerability to liability, but more important, to preserve the
meaning and authority of the psychiatrist's signature for the
profession at large.
AMERICAN ACADEMY OF CHILD & ADOLESCENT PSYCHIATRY
3615 Wisconsin Avenue, NW Washington, DC 20016-3007
202.966.7300 - FAX 202.966.2891
American Academy of Child & Adolescent Psychiatry
Policy Statement
Prescribing Psychoactive Medications for Children and
Adolescent
Adopted by the Council on June 16, 2000
Prescribing psychotropic medications for children and
adolescents requires the judgments of a physician, such as a
child and adolescent psychiatrist, with training and
qualifications in the use of these medications in this age group.
Certainly any consideration of such medication in a child or
infant below the age of five should be very carefully evaluated
by a clinician with special training and experience with this
very young age group. Any child or adolescent for whom medication
is a consideration requires an evaluation of the psychiatric
disorder, including the symptoms, co-morbid conditions, any other
medical conditions, family and psychosocial assessment and school
record.
Most psychoactive medications prescribed for children under
age 12 do not as yet have specific approval by the Federal Drug
Administration (FDA); such approval requires research
demonstration safety and efficacy. Such research so far lags
behind the clinical use of these medications. Efforts to address
this deficiency include the development of Research Units of
Pediatric Psychopharmacology (RUPP) and recent federal
regulations requiring increased studies of medications presented
for children and adolescents. Long-term studies are needed to
adequately determine the safety and efficacy of psychoactive
medications.
In making decisions to prescribe such medications the
physician - specifically the child and adolescent psychiatrist -
should consider data from studies in adults in treating the
target disorder and/or symptomatology, any clinical or anecdotal
reports of use in child and adolescent patients, studies
conducted outside the United States and the experience of
colleagues.
The prescribing of multiple psychotropic medications
("combined treatment"--"polypharmacy") in the
pediatric population seems anecdotally on the increase. Little
data exists to support advantageous efficacy for drug
combinations, used primarily to treat co-morbid conditions. The
current clinical " state-of-the-art" supports judicious
use of combined medications, keeping such use to clearly
justifiable clinical circumstances. ongoing medication management
requires the informed consent of the parents or legal guardians
and must address benefits vs. risks, side effects and the
potential for drug interactions.
It is important to balance the increasing market pressures for
efficiency in psychiatric treatment with the need for sufficient
time to thoughtfully, and adequately, assess the need for, and
the response to medication treatment. Monitoring on going
prescribing of psychoactive medications requires sufficient time
to assess clinical response, side effects and to answer questions
of the child and family.
AACAP opposes the use of brief medication visits (e.g.
15-minute medication checks) as the accepted standard of care by
the insurance industry; health plans and managed care companies.
The role of psychosocial interventions, including psychotherapy,
must be evaluated, and such interventions must be included in the
treatment plan.
This site is a supplement, not a substitute,
for professional help.
T. J. Glenn, M.D., F.A.P.A.,
F.A.A.C.A.P.
20450 Huebner Rd. #203
San Antonio TX 78258
E-mail - tglennmd@familymentalhealth.com
Fax - 210-495-5436