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OOSS SUPPORTS CMS PROPOSAL TO ELIMINATE H&P AND HOSPITAL TRANSFER AGREEMENT REQUIREMENTS

In September, CMS proposed reducing, modifying, or eliminating a number of obsolete, unnecessary, and burdensome regulations impacting a multitude of providers. In comments to the agency, OOSS is strenuously urging CMS to finalize and adopt three proposed provisions:

  • CMS proposed to replace the current requirement that every patient have a comprehensive medical history and physical examination within 30 days prior to surgery in an ASC with a requirement that allows the operating physician and ASC to determine which patients would require more extensive testing and assessment prior to surgery. ASCs would be required to establish and implement a policy that identifies patients who require an H&P assessment prior to surgery. The agency cited cataract with IOL implant and after cataract laser surgery as examples of procedures that should not routinely require a comprehensive H&P.
  • The agency also proposed to remove the provisions requiring facilities to have a written transfer agreement with a hospital or ensure that all physicians have admitting privileges in a hospital. CMS states that “this long-standing requirement is now duplicative of other regulatory requirements and has been rendered obsolete by other patient protections.” This should be good news for facilities and surgeons that have had difficulties securing these arrangements with hospitals.
  • CMS has also proposed to reduce several current requirements relating to emergency preparedness in ASCs.

We will keep you abreast of further developments. Should the proposed rule be finalized, OOSS will assist members in the development of policies and procedures that meet the requirements of the proposal.

I would like to acknowledge the tremendous assistance I received in developing our comments from Nikki Hurley, RN, MBA; Bob Nelson, PA-C; Larry Rabinowitz, MD; Maria Scott, MD; and Maria Tietjen, RN, BSN.

As you know, OOSS has a large agenda and we cannot achieve all of our objectives without your support. If you haven’t yet paid your dues, you may do so here. If you aren’t a member, we welcome you to join today.

Read OOSS’ full comments on the proposed rule.

Read the proposed rule on page 9 of this document.

Should you have any questions, please contact OOSS Washington Counsel Michael A. Romansky at mromansky@OOSS.org.