Revenue Cycle

CAH impact: Proposed Medicare Conditions of Participation changes

Medicare Update for CAHs, November 2, 2011

On Monday, October 24, CMS issued in the Federal Register a proposed rule that would revise the requirements—known as the Medicare Conditions of Participation (CoP)—that hospitals and critical access hospitals (CAHs) must meet in the Medicare and Medicaid programs.

The Conditions of Participation (CoPs) are federal health and safety requirements that ensure high quality care for all patients.  Hospitals and CAHs must meet these conditions to participate in the Medicare and Medicaid programs.  The following is a summary of some of the proposals that will, in some way, have an impact on critical access hospitals (42 CFR 485 section only):

Definitions (§ 485.602) and provision of services (§ 485.635)

CMS currently requires CAHs to furnish certain types of services directly rather than through contracts or under arrangements. The proposed rule would eliminate the requirement that the CAH staff must provide certain services directly and changes the heading of the standard “direct services” to “patient services.” It also proposes to revise the language in paragraphs§ 485.635(b)(1) through (b)(4), that the CAH staff furnishes as direct services.

Personnel Qualifications (§ 485.604)

CMS is proposing to revise the definition of a clinical nurse specialist at § 485.604(a) to reflect the definition in the statute at§ 1861(aa)(5)(B). Specifically, CMS proposes to change the definition to state that a clinical nurse specialist is a registered nurse licensed to practice nursing in the state in which the clinical nurse specialist services are performed and that holds an advanced degree in a defined clinical area of nursing from an accredited educational institution.

Surgical Services (§ 485.639)

CMS amended this section by revising the introductory text to read as follows: If a CAH provides surgical services, surgical procedures must be performed in a safe manner by qualified practitioners who have been granted clinical privileges by the governing body, or responsible individual, of the CAH in accordance with the designation requirements under paragraph (a) of this section.

There are a number of additional proposed changes included in this document that could have a significant positive impact on hospital procedures. CAHs are encouraged to review the entire proposed rule and submit comments no later than December 23, 2011.

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