Here's a sampling of the comments posted on regulations.org:
A 13-page letter signed by more than 80 physicians groups, including the AMA, the American Academy of Family Physicians and the American College of Surgeons, takes issue with proposed changes to the existing governance and medical staff regulations. The letter notes that CMS is not statutorily authorized to reduce the regulatory burden for hospitals or to address healthcare workforce shortages. "The statute limits CMS' authority to promulgate the CoPs in furtherance of the health and safety of hospital patients." The letter adds that the proposed changes "would be detrimental to the health and safety of patients in the hospital setting."
To allow one governing body to oversee multiple hospitals in a single healthcare system would "disenfranchise the patients of any hospital…that is unique among its member hospitals for any reason, including geographic location, services rendered and patient demographic," says the letter.
Stephen P. Blatt MD, president-elect of the Good Samaritan Hospital medical staff in Cincinnati, agrees saying, "allowing a single governing body to oversee all hospitals within a multi-hospital system would further remove the governing body from the daily operations, governance and medical staff affairs of each individual hospital. Governing bodies are essential for maintaining quality of care within hospitals and health systems and having them further removed from these issues will only worsen safety and quality of care."
No surprise that the American Hospital Association supports the governing change. "This change recognizes the more integrated organizational model adopted by many hospitals." The AHA asked CMS to clarify that hospitals with more than one CMS certification number may have a single governing body.
In its letter the AMA group also opposes allowing hospitals to grant privileges to physicians who are not on the medical staff of the hospital. The move would "allow a hospital to …exclude some physicians from the medical staff. This proposal would undermine the medical staff's chief function: self governance."