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AORN Comments on CMS’ Conditions of Participation

Publish Date: 12/28/2011

In an effort to have the Center for Medicare & Medicaid Services (CMS) look to future improvements in the Conditions of Participation, AORN submitted comments on December 19 regarding proposed reforms of outdated or unnecessary Hospital Conditions of Participation. The proposed rule of CMS would revise the requirements that hospitals and critical access hospitals (CAHs) must meet to participate in the Medicare and Medicaid programs. These proposed changes are an integral part of AORN’s ongoing efforts to reduce procedural burdens on providers.

To assure medical and clinical staff improvement, AORN recommended consideration of competency standards addressing the evaluation of continued competency of performance. And because nurses are responsible for many of the compliance and documentation requirements attendant to patient care, AORN applauded the agency’s commitment to reducing unnecessary regulatory burdens on hospitals while continuing to focus on maintaining important safety measures and quality of care protections for hospital patients.

AORN also praised CMS because the proposed rule reflects many of the positive changes for nursing recommended in the IOM’s recently released report, Future of Nursing: Leading Change, Advancing Health. The proposed rule preserves patient safeguards in the Conditions of Participation that are important to perioperative registered nurses, including the traditional and current role of nursing in providing direct patient care and supervising allied health care providers who perform delegated nursing functions.

In its comments, AORN supported CMS’s proposal to clarify that a hospital may grant privileges to both physicians and non-physicians to practice within their state scope of practice, regardless of whether they are also appointed to the hospital’s medical staff. AORN’s comments specifically highlighted that many RNFAs are privileged to perform first assistant at surgery services in Medicare-participating hospitals.

Many of the perioperative-specific issues highlighted from the AORN comments were also included in the comments to CMS from the American Nurses Association, the Nursing Community, and the Nursing Alliance for Quality Care.

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