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AAMC Comments on CMS Proposed Rule on Emergency Preparedness Requirements

April 4, 2014—The AAMC submitted March 31 comments  to the Centers for Medicare and Medicaid Services (CMS) regarding the Emergency Preparedness Requirements proposed rule. Through these requirements, CMS aims to amend the Conditions of Participation (CoPs) and Conditions for Coverage (CfCs) for 17 Medicare and Medicaid provider and supplier sectors.

In the comment letter, the association addressed the proposed changes affecting transplant centers. The AAMC stated that such requirements are unnecessary given the close cooperation of transplant centers across the country. The association also noted that the Joint Commission and other accreditation bodies already require these centers to have disaster contingency plans in place which fulfill the spirit of the requirements proposed in the rule. The AAMC additionally relayed information from member institutions that predicted a much higher cost and time burden to fulfill these requirements than what was estimated by CMS.

Under the rule, CMS would require all transplant centers to have an agreement with at least one other Medicare-approved transplant center to provide transplantation services and other care for its patients in an emergency. This agreement would need to address two issues:

  • The circumstances under which the agreement would be activated; and
  • The types of services that would be provided during an emergency.

In addition, CMS also proposes a new requirement for transplant centers and the organ procurement organization (OPO). A transplant center would now be required to ensure that the hospital in which it operates has a written agreement with the OPO that addresses duties and responsibilities of hospitals and the OPO during an emergency.


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