Letter: Proposed Rule on Reducing Burden of Conditions of Participation

The AHA comments on the Centers for Medicare & Medicaid Services’ proposed rule on burden reduction, program efficiency and transparency with regard to Medicare Conditions of Participation. Specifically, our letter addresses proposed changes in reporting requirements, ambulatory surgery center and hospital provisions, and proposals surrounding preoperative medical history and physical examination requirements.

Download the letter (PDF) below


Re: CMS—3346—P, Medicare and Medicaid Programs; Regulatory Provisions To Promote Program Efficiency, Transparency, and Burden Reduction; Proposed Rule (Vol. 83, No. 183), Sept. 20, 2018.

The AHA supports the proposals to allow health care systems to opt to take a system-wide approach to Quality Assurance and Performance Improvement and Infection Control with oversight from the system governing board; change current Medicare reapproval requirements for transplant centers; and change the frequency and nature of emergency preparedness testing requirements for hospitals.

However, we strongly oppose the removal of the requirement that ASCs have a written agreement or physician admission privileges with hospitals. Further, we have some concerns with the proposed elimination of current preoperative medical history and physical examination requirements in lieu of ASCs and hospitals establishing their own requirements.

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