NAPH Submits Comments on Conditions of Participation Proposed Rule - December 20, 2011

NAPH submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its proposed rule revising the existing Conditions of Participation (CoP) for hospitals. In its Dec. 15 letter, NAPH supported many of the proposed revisions. In particular, NAPH supported the proposed changes to the CoPs that would allow one governing body to oversee multiple hospitals in a single health system and enable hospitals to develop a single, interdisciplinary care plan for patients that supports coordination of care, rather than requiring a separate, standalone nursing care plan. NAPH also supported CMS’ proposal to give hospitals greater flexibility in determining the management structure of their outpatient services by allowing them to assign one or more individuals to oversee those services. NAPH recommended that CMS consider updating the CoPs to reflect the most up-to-date Life Safety Code edition instead of referencing a specific edition, as it has done previously. This update would streamline hospital compliance to the Life Safety Code for various survey and accreditation agencies.

If you have any questions, please contact Xiaoyi Huang at xhuang@naph.org or 202-585-0127.