Comments on the Medicare Recommendations
Governing body (482.12)
If passed, CMS will permit one governing body to govern component system hospitals with separate CCNs. This is probably a moot change, since most systems are doing this anyway, but they are keeping separate businesses and minutes for each individual hospital.
Patient’s Rights (482.13)
Medicare has modified the reporting requirements of patients who die in restraints or die within a time period of being restrained. The modification applies to patients who are restrained in 2-point restraints but are NOT secluded.
The reporting requirements have not gone away! However, now they can be reported within 7 days by means of a log of other similar device that contains patient’s name, date of birth, date of death, attending physician, primary diagnosis, and medical record number.
Be aware that deaths are STILL required to be reported.
Medical Staff (482.22)
This section is more or less moot. CMS had decided to change requirements that reflect that medical staffs have been doing all along: granting privileges without medical staff membership.
Many medical staffs have developed non-member categories and privilege such physicians and locum tenens, or limited privilege community physicians without requiring the obligations of medical staff membership.
Be aware: As proposed, all who order care, treatment or services STILL must be granted privileges. However, it DOES open the door for potential ordering of medications by PharmDs if allowed by law and regulation.
A third change would allow podiatrists to serve as President of the Medical staff. Again, this is probably a moot issue because if they are medical staff members, they should, by other standards, be eligible for officer positions in the medical staff.
CMS appears to be stating that they do NOT require one medicals staff per CCN, but this is not how TJC or state CMS surveyors have approached this issue. However, if this becomes official, it will open the door to one system medical staff with component hospitals.
Nursing Services (482.23)
This standard if changed would allow nursing care plans to be integrated into interdisciplinary care plans. Those with good care plans have already done this. This is not a dramatic change.
A more significant change is the permission to, as defined by the medical staff, for nurses to use standing orders. It clearly states though that no decision-making can occur by a nurse on which orders to implement or any decision on dosing. Also required would be the criteria for implementation be carefully and precisely defined.
Another change is dropping the requirement for special training for blood transfusion and medication administration. Again, most hospitals are already doing this but not always is it specifically clear.
Medical Records (482.24)
The permission for partners to authenticate verbal orders on behalf of physicians will be extended. This rule was to expire on January 26, 2012.
Also CMS had now taken the position that verbal/telephone orders may be authenticated within a time frame it defines and will no longer require a maximum of 48 hours. Unfortunately most states have laws that are more stringent.
Infection Control (482.42)
Infection control “logs” no longer are required.
Outpatient Services (482.54)
CMS will no longer require that “one person” be designated as responsible for all outpatient and ambulatory services.
CMS will no longer will require various repeated blood typing requirements.