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If an NP or CNS is not employed by the SNF but is employed by an organization related to the SNF, may he/she sign the certification and re-certifications?

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If an NP or CNS is not employed by the SNF but is employed by an organization related to the SNF, may he/she sign the certification and re-certifications?

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A14. The requirement in 42 CFR § 424.20(e) is specific in that an NP or CNS “neither of whom has a direct or indirect employment relationship with the facility” may sign the certifications and re-certifications. In this case, the NP or CNS is not an employee, but has an indirect employment relationship and, thus, are not permitted to sign the certifications and re-certifications.

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A14. The requirement in 42 CFR § 424.20(e) is specific in that an NP or CNS “neither of whom has a direct or indirect employment relationship with the facility” may sign the certifications and re-certifications. In this case, the NP or CNS is not an employee, but has an indirect employment relationship and, thus, are not permitted to sign the certifications and re-certifications.

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