Revenue Cycle

November 22, 2011 Hospital & Hospital Quality Open Door Forum Summary

Recovery Auditor Report, December 29, 2011

Hospital and CAH conditions of participation proposed rule

A CMS representative came on the line to walk through some of the major provisions of the hospital and CAH conditions of participation proposed rule. They are as follows:

  • CMS proposes to revise the conditions at 482.12, the Governing Body, to allow one governing body to oversee multiple hospitals in a single healthcare system.
  • CMS proposes changes to the medical staff conditions to clarify the policy to allow hospitals the option to grant privileges to physicians and non-physicians to practice within their state’s scope of practice regardless of whether or not they own a hospital’s medical staff. With the proposal, all practitioners would f unction under the rules of the medical staff and the medical staff would continue to evaluate credentials and make recommendations to the hospital’s governing body.
  • CMS proposes to allow hospitals to have a stand-alone nursing care plan or a single integrated care plan that addresses nursing and other disciplines.
  • CMS proposes to allow a hospital to set up a program whereby a patient or support person can self-administer both hospital-issued medications and the patient’s own medications brought into the hospital as set forth in the hospital’s policies and procedures.
  • CMS proposes to revise the condition regarding medical record services, and one of the proposals it’s made is to encourage hospitals to use pre-printed and electronic standing orders and order fax.
  • CMS proposes to make permanent the current requirement that all orders, including verbal orders, must be dated, timed and authenticated by either the ordering practitioner or another practitioner who is responsible for the care of the patient and who’s authorized to write order by hospital policy in accordance with state law. CMS also revised the condition regarding outpatient services by proposing to remove the requirement for a single director of outpatient service division that oversees all outpatient departments in a hospital.
  •  Lastly, CMS proposes to eliminate the requirement that CAHs must directly furnish diagnostic and therapeutic services, lab services, radiology services and emergency procedures. This proposal would allow CAHs to provide such services under arrangement.

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