The Controversy - 2012 Rulemaking Attempts
Roughly two years ago, the Centers for Medicare and Medicaid Services of the Department of Health and Human Services ("CMS") published final regulations announcing two controversial rule changes addressing hospital governance. The industry was taken by surprise, to say the least, as neither of these requirements had been in the proposed rule. The changes, promulgated as amendments to the Governing Body Condition of Participation (CoP) included (i) the requirement that a hospital's board include at least one member of ...
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