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Washington Highlights

AAMC Submits Comments on CMS Proposals on Hospital Conditions of Participation

April 19, 2013—In an April 4 comment letter  to the Centers for Medicare and Medicaid Services (CMS), the AAMC raised several concerns regarding the proposed rule, Part II-Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction, which sought to revise and clarify some of the hospital conditions of participation (CoPs).

The AAMC objected to the CMS clarification that each hospital must have its own medical staff.  The association also asked the agency to confirm that the proposal to require that orders for outpatient services must be made by a practitioner who is “responsible for the care of the patient; acting within his or her scope of practice under State law; and authorized in accordance with policies adopted by the medical staff, and approved by the governing body, to order the applicable outpatient services” will not preclude residents from ordering those services.

In addition, the AAMC signed an April 18 letter  with the American Hospital Association, National Association of Public Hospitals and Health Systems, Federation of American Hospitals, and Children’s Hospital Association, that raised significant concerns about the CMS position that it was clarifying that each hospital must have its own medical staff so that a multi-hospital system would not be able to have a unified medical staff. 

The associations asked CMS to withdraw this clarification and instead “enable hospital systems and their affiliated medical staffs to decide, together, what medical staff structure works best for their patients.” 


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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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
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806