QUESTION: The five medical staffs in our system are thinking about unifying. Are there any particular steps we need to follow and any changes we need to make to our bylaws?
ANSWER: In May 2014, CMS revised the Medicare Conditions of Participation to allow a multi-hospital system to have a unified and integrated Medical Staff. There are several steps that must be taken in the integration process. First, the system must ensure that there is nothing in the state hospital licensing statutes or regulations that would prohibit the medical staffs of separately licensed hospitals from integrating into a single staff.
Second, the Board (and there must be a single Board) must document in writing its decision to use a unified medical staff model. This decision would be conditioned on acceptance by the hospitals’ medical staffs to opt-in to an integrated medical staff model.
Third, the medical staff of each of the hospitals must take a separate vote to opt in or opt out of the unified medical staff. The vote at each hospital must be governed by the respective medical staff bylaws in effect at the time. Only voting members of the medical staff who hold privileges to practice on site at the hospital may participate in the vote.
Fourth, the unified medical staff will also want to adopt new medical staff bylaws and related policies. The new bylaws should take into account the unique circumstances of each hospital, including any significant differences in the patient populations and the clinical services that are offered at each hospital.
Importantly, the new bylaws must also include a process by which the voting members of the medical staff who exercise clinical privileges at the hospital may vote to opt out of the unified medical staff in the future.