On May 12, 2014, the Centers for Medicare and Medicaid Services (CMS) published a long-awaited final rule, officially permitting medical staffs from hospitals within a multi-hospital system to unify. CMS further clarified the requirements for such unification in interpretive guidelines published Sept. 15, 2014. The interpretive guidelines strike a balance between the authority of a hospital or system’s governing body and that of the medical staff. All hospitals should carefully consider the new CMS requirements if they are part of a larger health system. In addition, systems that are contemplating expansion should also consider how a unified medical staff could impact future transactions.
A health system hoping to unify the medical staffs of separately licensed hospitals must comply with a number of CMS requirements. Decisions must be made regarding how the unification will be implemented, how it can be unwound, and how “local” matters will be addressed. Even if hospitals within a system are not currently contemplating a unified medical staff, a process for consideration of the issue at a future time must be documented and the medical staff bylaws amended.
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