CMS Proposing New Hospital Regulations—How Will the Changes Affect Your Delivery of Care?

The below information on proposed changes has been shared with AJN by Jeannie Miller, MPH, RN, Deputy Director, Clinical Standards Group, Office of Clinical Standards and Quality (CSG/OCSQ) of the Centers for Medicare and Medicaid Services (CMS).

The Centers for Medicare and Medicaid Services (CMS) has proposed revisions to the hospital Conditions of Participation, the criteria hospitals must meet to be reimbursed for services by Medicare/Medicaid. The changes are needed to remove unnecessary and burdensome regulations that create barriers in care delivery. The changes, if adopted, include:

  • Broadening the concept of “medical staff” to include other practitioners, including APRNs, PAs, and pharmacists, practicing within their scope of practice and in accordance with state law.
  • Changes in nursing care planning to allow for a stand-alone plan or an integrated plan with other disciplines.
  • Allowing medication orders by practitioners other than physicians where the law and hospital policy allows.
  • Allowing a program for patient or “support person” to administer some medications.
  • Calling for standing orders and protocols to be based on nationally recognized and evidence-based guidelines.

There is a 60-day comment period. The CMS would like your comments. The proposed regulation can be found in full via a link on this page near the bottom: Or go directly to the PDF here.

To submit a comment, visit, enter the ID number CMS-3244-P, and click on “Submit a Comment.” 

2016-11-21T13:11:42+00:00 October 18th, 2011|career|6 Comments

About the Author:

Senior editor/social media strategy, American Journal of Nursing, and editor of AJN Off the Charts.


  1. Terri Schmitt (@onlinenursing) October 20, 2011 at 9:58 am

    Thanks for reviewing this. I was somewhat concerned with new CMS changes at first, but this wording is more clear to me. My principle concerns were that nursing care plans were going away. Were they not effective? Were they not being utilized properly? However, collaborative care plans where nurses can and should write orders, consultations (like diabetes education, social work), and where nurses can make obvious decision for the patient (like holding a B/P medication if the pt. is hypotensive) without physician orders. Currently, one of the health systems I work with does not allow any of this.
    I was also concerned about the primary care changes like not requiring some emergency equipment in some clinics, but if their is evidence to back these changes and if nurses are coming more to the table and not being relegated to a further back seat or less decision making, then I am very good with them. Thank you for clarifying.

  2. jm October 19, 2011 at 11:54 am

    Vernon, good points. It would great if you could say more about what you mean by “the utilization of nurses at the bedside.” Are you saying that not enough RNs are doing bedside care, which is often relegated to support staff who are less expensive to employ? Or something else? And can you give any examples of when this might be a problem, based on your experience? Specifics would be of interest to us. Also, separately: do you see any of the other proposed changes, such as those affecting standing orders or those affecting nursing care plans, as potentially helpful?–JM

  3. Vernon Dutton October 18, 2011 at 9:00 pm

    I think the proposed revisions are wonderful for Nurse Practitioners. It seams to me that the CMS should advocate for safe nurse staffing and should address the utilization of nurses at the bedside, in addition to utilization of advance practice nurses.

    The nurse at the bedside was all but left out of the (Future Of Nursing) report and recommendations, which has been a factor in getting hospital nurses to support it. Unsafe staffing and the ridiculous utilization of hospital nurses is the biggest problem in healthcare and the one most often ignored.

  4. Amanda October 18, 2011 at 5:32 pm

    I personally would not feel comfortable dispensing medications to a “support person” so that they could give the medications for me. I have never pulled medications and allowed someone else to administer them and I would not feel comfortable doing so unless I sat there and watched the medications being given.

  5. Samuel Logan October 18, 2011 at 4:09 pm

    Doesn’t support persons regard to family members or friends? If that’s the case I think it’s a great idea. It gives nursing the opportunity to educate them, build a stronger support system, and can cut down on nursing time.

  6. Kerry B. October 18, 2011 at 3:27 pm

    Not too keen on whether ” support person” should give medications.Licensed practical nurse (LPN) do give medication in all states.There should educational programs that support an increase of LPNs in communities as well as registerd nurses (RN)programs. The shortage is going to get worse if programs are not in place.

Comments are moderated before approval, but always welcome.