Call for Comments about CMS Hospital Conditions of Participation

Think about commenting on this proposed regulation and its impacts on you, your practice, and your information system solutions.

The Centers for Medicare and Medicaid Services (CMS) has proposed revisions to the hospital Conditions of Participation, the criteria hospitals must meet to be reimbursed for services by Medicare/Medicaid. The changes are needed to remove unnecessary and burdensome regulations that create barriers in care delivery. The changes, if adopted, include:

  • Broadening the concept of “medical staff” to include other practitioners, including APRNs, PAs, and pharmacists, practicing within their scope of practice and in accordance with state law.
  • Changes in nursing care planning to allow for a stand-alone plan or an integrated plan with other disciplines.
  • Allowing medication orders by practitioners other than physicians where the law and hospital policy allows.
  • Allowing a program for patient or “support person” to administer some medications.
  • Calling for standing orders and protocols to be based on nationally recognized and evidence-based guidelines.

There is a 60-day comment period. The CMS would like your comments. The proposed regulation can be found in full via a link on this page near the bottom: Or go directly to the PDF here.

To submit a comment, visit, enter the ID number CMS-3244-P, and click on “Submit a Comment.” 

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