New Medicare Conditions of Participation for Hospitals

The new Medicare Conditions of Participation for Hospitals are reviewed, and their effect on hospital pharmacy is discussed. In general, the revised Conditions, which are federal regulations establishing requirements that hospitals must meet to participate in Medicare programs, focus on outcomes and services rather than on procedures and departments. A new standard requiring discharge planning as part of an institution's quality-assurance program implicitly invites pharmacy participation by not limiting responsibility for such a program to the medical staff. The medical staff is accountable to the governing body, rather than co-equal with it, as was the case previously. Hospitals now have greater flexibility in granting staff privileges to nonphysician practitioners; pharmacists could be designated as a category of medical-staff membership. The opportunity exists for initiation and expansion of pharmacy-based medication-administration programs, since the Conditions do not limit such services to nursing or medical personnel. Pharmacists are permitted to receive oral orders for prescriptions. The importance of pharmaceutical services is recognized in the new standards by requirements for drug-therapy monitoring and information and drug-product control. Further, the regulations mandate establishment of a formulary system. The pharmacy-related changes in the Conditions recognize several key professional practice concepts, thus easing implementation of new strategic directions for hospitals and hospital pharmacy.