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AAMC Comments on Hospital Conditions of Participation Proposed Rule

January 6, 2012—The AAMC Dec. 22, 2011, submitted comments  on the Centers for Medicare and Medicaid Services (CMS) proposed rule updating hospital conditions of participation (CoPs). The CoPs are requirements that hospitals must follow to participate in the Medicare and Medicaid programs. The proposed rule is the first comprehensive update to the CoPs since 1986 and is estimated to save approximately $900 million annually through the removal of unnecessary and outdated regulations.

The AAMC was generally pleased with the changes proposed and focused its comments on clarifying the role that resident physicians would have under the standing orders and verbal orders authentication requirements. The AAMC also recommended that CMS convene a group of stakeholders and individuals to develop and assess the interpretive guidelines, which form the basis for hospital surveys.

In the proposed rule, CMS recommended that multi-hospital systems be allowed to have a single governing body, instead of a separate governing body for each institution as is current policy. CMS also proposed granting hospitals greater flexibility in determining the management structure of outpatient services and would allow hospitals to assign one or more individuals to be responsible for these services. CMS made additional recommendations pertaining to hospitals’ medical staffs, transplant centers, nursing services, and verbal order authentication requirements. 


Scott Wetzel, M.P.P.
Lead, Quality Reporting
Telephone: 202-828-0495


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
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Telephone: 202-903-0806