APAPO supports full hospital medical staff membership for psychologists

APAPO submits comments to CMS regarding requirements for hospital participation in Medicare and Medicaid

by Legal and Regulatory Affairs Staff

January 12, 2012—The Centers for Medicare and Medicaid Services (CMS) recently released proposed revisions to their requirements for hospitals and critical access hospitals to participate in Medicare and Medicaid. According to CMS, these proposed revisions were designed to reduce regulatory burden and system costs by removing or revising obsolete and unnecessary provisions. In addition, CMS goals included increasing flexibility and improving clarity. The APA Practice Organization (APAPO) submitted a letter (PDF, 40KB) supporting these general goals and commenting in more detail on proposed changes to the condition of participation relating to the composition of hospital medical staff.

APAPO specifically offered its support for the following CMS goals:

  • Providing hospitals the “clarity and flexibility they need to maximize their staffing opportunities for all practitioners, and particularly for non-physician practitioners.”
  • Clarifying that “a hospital may grant privileges to both physicians and non-physicians to practice within their State scope of practice, regardless of whether they are also appointed to the hospital’s medical staff.” (76 FR 65893)

However, APAPO’s comments raised a concern that the proposed changes to the medical staff rules could encourage hospitals to adopt different categories of medical staff membership that would put all non-physicians practitioners, including psychologists, on a lower tier than physicians. This type of staff structure could interfere with the ability of non-physician practitioners to participate fully and appropriately in matters pertaining to their areas of expertise.

In order to facilitate better and more integrated care in hospitals, APAPO urged that all qualified non-physician professionals, including independently licensed practitioners with doctoral-level training such as psychologists, be given an opportunity to participate fully on the medical staff.

APAPO’s comment letter is consistent with the APA Guidelines for Psychological Practice in Health Care Delivery Systems (PDF, 245KB). These guidelines recommend that psychologists to seek the highest level of staff membership and broadest range of privileges consistent with their training and expertise. They also suggest that psychologists become involved in programs, services and departmental leadership, and seek appointments to relevant medical staff committees.

For more information, contact the Legal and Regulatory Affairs department by email or at (202) 336-5889.