Proposed Rule: Hospital and CAH Changes to Promote Improvements in Patient Care

06/14/16  Portland, Ore.

On June 13, CMS released a proposed rule to make changes to the Medicare and Medicaid Conditions of Participation (COPs) for all hospitals and CAHs.

The current hospital COPs are codified in regulation at 42 CFR Part 482 while the CAH COPs are at 42 CFR Part 485, Subpart F. The COPs are further interpreted by CMS in the State Operations Manual which provide guidance to people who survey hospitals and CAHs to make sure they meet the COPs and tells hospitals and CAHs what to expect at their surveys. Significant proposed changes for CAHs include standards for:

  • Maintaining a data-driven quality assessment and performance improvement (QAPI) program.
  • Written non-discrimination policies;
  • Regularly evaluating the care provided by practitioners at the CAH;
  • Maintaining active infection prevention, infection control, and antibiotic stewardship programs.

Of particular note for CAH stakeholders, the discussion of CAH QAPI programs recognizes the FORHP-supported Flex Medicare Beneficiary Quality Improvement Project (MBQIP) as a national quality measurement and reporting program. The proposed rules would require CAHs to collect data to measure the quality of care they provide and CAH participation in MBQIP is one way for CAHs to meet this data collection requirement.

Rural stakeholders and CAHs should review the proposed rule and submit public comments before August 15, 2016. Specific, actionable comments and suggested alternatives related to identified policies can help CMS develop the final regulation for CAHs and hospitals.