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New Medicare rules authorize multi-hospital systems to establish system-wide medical staffs

May 29, 2014
Area(s) of Interest: Hospitals and Health Facilities Medical Staff Self Governance 


The Centers for Medicare and Medicaid Services (CMS) published a final rule on May 7, 2014, concerning its participation requirements for hospitals, known as "Conditions of Participation." The California Medical Association (CMA) commented extensively on this and prior iterations of this rulemaking. This final rule is the latest in a series of CMS rules intended to reduce regulatory burdens, and focused in part on guidelines for medical staffs.


Major provisions of the final rule related to medical staffs are:


  • Multi-hospital systems may have the option of having a single unified and integrated medical staff, but a majority of each medical staff must affirmatively vote to accept a unified and integrated medical staff structure or to opt out of such a structure and to maintain a separate and distinct medical staff for their respective hospitals.

  • The final rule does not require members of the medical staff to serve as representatives on the hospital governing body. However, hospital governing bodies must periodically throughout the year consult directly with a medical staff member from each medical staff within the multi-hospital system.

  • While the final rule contains provisions that CMA opposed, CMA will be working to help medical staffs inform their membership on how to best influence the path forward (i.e., to join or not join a system-wide medical staff) and, if they decide to join an integrated medical staff, how to best structure consultations with the governing body.


    It is unlikely that CMS will revisit this regulation in the near term, but CMA will continue to look for advocacy opportunities to advance physician leadership in hospital and other settings.


    Contact: Yvonne Choong, (800) 86-4262 or ychoong@cmadocs.org.

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