Conditions of Participation

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The Centers for Medicare and Medicaid Services (CMS) issued a proposed rule in the October 24 Federal Register that revises the requirements – commonly referred to as Conditions of Participation (CoPs) - that hospitals and critical access hospitals must meet to participate in the Medicare and Medicaid Programs.

CoPs are designed to protect patient health and safety and ensure quality of care, and can sometimes limit or prohibit nurses from practicing to the full extent of their education and training.  CMS is proposing changes in the CoPs which will impact nursing practice and patient care within these hospitals – and potentially throughout health care.

These changes could break down barriers that can limit nursing practice.  The proposed rule changes requirements related to many of the things nurses do every day - use of restraints and seclusion, hospital privileging and APRN practice, nursing care plans, standing orders, and verbal order review and authentication.

CMS requested comments on these proposals, and received thousands, including from ANA and other nurses.  The final rule was issued in the May 16 Federal Register, and included a detailed summary of the comments and CMS' response to them.  ANA has analyzed this narrative and the final rule in comparison to our comments, and other issues that impact nurses.  In some cases, ANA's comments and suggestions were successful.

Overall, the revised CoPs represent a significant acknowledgement of nursing's contribution and leadership in hospital care; however, efforts are still needed to ensure nursing is a full partner in the transformation of health care.  ANA will continue its advocacy to CMS to assure nursing's voice in hospital care and leadership.

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