fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

FAH Comments to CMS on Proposed Additions and Changes to Hospital Conditions of Participation

August 17, 2016 | FAH POlicy Blog Team

Category: Health Care Delivery, Medicare, Quality

The Federation of American Hospitals submitted comments to CMS on Monday in response to the agency’s proposed rule on the creation of a new anti-biotic stewardship program and updating of anti-discrimination and overall hospital quality improvement.

Specifically, the proposed new Conditions of Participation (CoPs) establish standards for hospital antibiotic stewardship and infection prevention and control programs, improved Quality Assessment and Performance Improvement (QAPI) programs, and updated patient’s rights programs in hospitals.  The goal of the proposed changes is to promote innovation, flexibility, and improvement in patient care.

FAH expressed overall support for the antibiotic stewardship (ASP) and infection control program additions to the CoPs, while at the same time cautioning CMS that the development of Interpretive Guidance (IGs) will be key to making the new standards work. FAH advocated for reasonable flexibility in implementation to ensure good, effective communication and coordination among patients, hospital leadership and infection control and pharmacy professionals.

Other topics highlighted in the letter address:

  • Implementation of new CoPs on patient’s rights addressing new civil rights requirements for gender identification and the alignment of the CoPs with requirements of the Office of Civil Rights
  • Medical Record Release Requests
  • Translation Services

FAH looks forward to working with CMS on this issue.