Hospital-Based Outpatient Clinics Committee

The Centers for Medicare & Medicaid Services (CMS) has released a proposed rule, attached, intended to reduce regulatory burden on health care providers. The proposed rule addresses several areas of regulation, including revisions to the Conditions of Participation (CoPs) for hospitals and critical access hospitals (CAHs), and changes to regulations under the Clinical Laboratory Improvement Amendments of 1988. It also solicits comments on reducing barriers to services for rural health clinics. Specifically, CMS proposes to eliminate the requirement that CAH staff provide outpatient diagnostic therapeutic services and allow them to contract out these services, eliminating the CMS requirement that physicians be onsite every two weeks. In addition, CMS proposes rescinding the regulation that hospital governing boards must include a member of the medical staff. Unfortunately, the proposed rule continues to require that each hospital have a dedicated medical staff rather than allowing for one integrated medical staff across a health system. This rule covers a number of important but disparate issues. CHA is currently reviewing the proposed rule and will develop a comprehensive summary in the coming weeks. CHA looks forward to working with members in developing comments to the proposed rule, due April 8.