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AAMC Submits Comment Letter on Medicare Conditions of Participation Proposed Rule

November 30, 2018—The AAMC Nov. 19 submitted a comment letter in response to the Centers for Medicare and Medicaid Services (CMS) proposed rule to change Conditions of Participation (CoP) requirements under Medicare and Medicaid. According to CMS, the proposals would reduce regulatory burden and improve quality of care.  

In the comment letter, the AAMC outlined its support of CMS’s efforts to reduce administrative burden and agreed with removing some requirements to allow providers to decide the best treatment options for their patients. 

The AAMC also supported the proposed changes to transplantation requirements to encourage use of all viable organs, citing that too many Americans die each year waiting for organ transplants. Additionally, the AAMC supported the proposal to defer to the physician’s clinical judgment when deciding if a comprehensive history and physical is required prior to surgery.  

The AAMC did not support proposed changes to eliminate the requirement for transfer agreements between hospitals and ambulatory surgical centers (ASCs). These agreements allow hospitals to understand the capacity at different ASCs which helps to facilitate care transitions if the need for transfer arises.


Mary Mullaney
Director, Hospital Payment Policies
Telephone: 202-909-2084


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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