ASA Urges CMS Revise Proposed Rule Changes on Conditions of Participation and More

On December 12, 2012, ASA formally addressed the Centers for Medicare & Medicaid Services’ (CMS) proposed rule changes (CMS-3244-P & CMS-9070-P)  related to hospital and critical access hospital conditions of participation and ambulatory surgery center emergency equipment. Additionally, due to strong lobbying by ASA, the remarks thanked CMS for maintaining the current federal physician supervision safety standard for anesthesia services. 

ASA strongly urged CMS to remove the “proposal that would allow physicians and non-physician providers to obtain hospital privileges without becoming a member of the medical staff.”  The remarks continued that “the hospital medical staff is the most qualified body to determine the qualifications required of, and ultimately review and approve or deny privileges for providers to safely treat patients in its respective hospital.”

ASA also expressed serious reservations regarding a proposal to expand the types of practitioners who may administer drugs and biologics.  In urging CMS to withdraw this proposal, ASA explained that the CDC attributes 15,000 a deaths a year due to overdoses of opioids with nearly all of the cases coming from prescriptions rather than pharmacy thefts.  Similarly, ASA urged CMS to revisit a “proposal to ensure that non-physician providers have the adequate training needed to successfully administer blood transfusions and intravenous medications.”

Finally, ASA opposed removing the list of emergency equipment in Ambulatory Surgery Centers required by CMS Conditions for Coverage.  ASA offered additional equipment that should be included in the list.

Click here and here to review ASA’s formal remarks regarding these proposed changes. 

The CMS proposed rules may be found here and here.