CMS Revised Hospital Conditions of Participation Now in Effect

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On July 16, 2012, in response to the President’s Executive Order directing federal agencies to achieve a more streamlined and efficient regulatory framework for hospitals, a final rule revising hospital and critical access hospital (CAH) Conditions of Participation (CoPs) became effective. The CoPs revisions are expected to reduce the total regulatory burden for hospitals and CAHs by nearly $940 million initially and $5 billion over the next 5 years.

Hospital Governing Body & Medical Staff Requirements -

The final rule included two significant substantive changes to the hospital governing body requirements that had not been previously addressed in proposed rulemakings. First, the Centers for Medicare & Medicaid Services (CMS) now permits one governing body to oversee multiple hospitals in a multi-system hospital system; and second, CMS added a requirement that at least one member of a hospital’s medical staff be included on the governing board to ensure effective communication and coordination between a single governing body and the medical staffs of individual hospitals in the system.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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