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CHA Voices Concerns Regarding Patient Notification Proposed Rule

CHA issues letter to CMS

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CHA sent a letter this week to the Centers for Medicare & Medicaid Services (CMS) voicing concerns regarding a CMS proposed rule on patient notification. The proposed rule would implement several changes to the current Medicare Conditions of Participation (CoP), and require hospitals and other providers to notify Medicare patients in writing of their right to file a written complaint with a Quality Improvement Organization.

The proposed rule also would require certain Medicare providers and suppliers to provide all patients with contact information for the state survey agency if they wish to file a complaint, and would require providers to document in the medical record that written notice was presented to the beneficiary or beneficiary’s designee.

CMS’ proposed modifications to the Medicare CoPs would make an already complex and paper-driven documentation process more cumbersome. Further, CMS ignores the current patient-complaint protocols already in place by health care provider and supplier organizations around the country. The proposed rule would unnecessarily add significant administrative costs to the health care system; create undue administrative burden on providers without improving the quality of patient care; and further confuse patients.

CHA urged CMS to proceed in implementing a systematic process for coordination of patient complaints among state survey agencies, The Joint Commission and other accrediting bodies, including state medical boards. To accomplish this goal, CHA urged CMS to consider a national patient complaint clearinghouse similar to the national Recovery Audit Contractor claims clearinghouse to help eliminate duplicative investigations and multiple requests of the hospitals to provide information on the same complaint.

For more information on the proposed rule, see attached CHA memorandum. The CHA letter is also attached.