In a formal comment letter to the Centers for Medicare & Medicaid Services (CMS), the Texas Medical Association, the American Medical Association, and more than 80 other medical societies urged the agency to give hospital medical staffs more time to study and prepare to implement a new rule that makes "unprecedented changes to the Medicare hospital Conditions of Participation (CoPs) that will dramatically alter the make-up and efficacy of hospital medical staffs nationwide."
The letter addressed a provision of the final rule, published May 12, that allows multihospital systems to elect a single integrated medical staff structure and provides that individual hospital medical staffs may opt in or opt out of this structure. Nevertheless, these regulations took effect July 11. TMA, AMA, and the other organizations asked CMS to delay the effective date of the provision until May 12, 2015, one year after the final rule's publication.
"Most medical staffs are unaware of or unprepared for the impending decision to either integrate into a single model or opt-out, and will undoubtedly be ill served by the expediency of these requests. CMS should give medical staffs both clarifying guidance as well as more time to understand and explore these issues," the letter to CMS Administrator Marilyn Tavenner states.
The signatories said medical staffs needed more time to understand the CoPs changes and a number of implementation issues not addressed in the rule.
Among the issues warranting further examination was licensure. The letter poses the following question: "In large, multi-state hospitals, will physicians who become a part of a single integrated medical staff be required to be licensed in each state in which the hospital provides services?" The letter elaborates, saying such a requirement "could create significant logistical issues and add to physicians’ administrative burden and is an issue that requires clarification."
Action, July 15, 2014