Hospital Association of Pennsylvania > Advocacy > Health Care Facility Licensure > Letter to DOH on Hospital Licensure Recommendations


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Letter to DOH on Hospital Licensure Recommendations

August 17, 2015

Dr. Karen Murphy
Secretary of Pennsylvania Department of Health
625 Forster Street, 8th Floor West
Health & Welfare Building
Harrisburg, PA 17120

Dear Secretary Murphy:

As you and I have discussed during the past several months, health care delivery is in a transformational stage. Pennsylvanians have greater access to health insurance coverage, health care providers and payers are focused on models of integrating payment with quality, and technology is providing unprecedented access to information and new delivery methods.

During this transformational time, the Department of Health regulatory role is important in assuring Pennsylvanians the care they are receiving is of high quality and safe. Unfortunately, with hospital regulations largely dating back to the early 1980s, it can be challenging to enable innovation that meets community needs.

During the past year, HAP worked with its members to evaluate areas of the existing hospital licensure regulations in which flexibility could be provided while at the same time assuring access to quality care.

Our recommendations include approaches to effective organizational and clinical structures in multi-hospital health systems and to assuring access to hospital care in underserved communities.

In addition, HAP’s recommendations also consider approaches to aligning state regulations with the Medicare conditions of participation (MCoP), provided that such conformance would be consistent with the state’s Health Care Facilities Act (Act 48 of 1979).

HAP is prepared to submit specific regulatory recommendations to the Department of Health quality assurance staff for consideration:

  • Issues which the hospital community believes would be best addressed by aligning state regulations with the MCoPs include: verbal orders; medical staff membership; medical staff privileges across a multi-hospital system; emergency services; dietetic services; radiologic services; surgical services; and outpatient services.
  • Issues which the hospital community believes would be best addressed in regulatory amendments include: pharmacy service use of lockboxes; management of environmental services across a hospital system; and elimination of a professional library given the use of the Internet at hospitals.

The attached chart provides the suggested change and the rational for the change. HAP will provide further detail to your staff in the near future to assist in their consideration.

I know that the Department and HAP share a mutual goal of assuring all Pennsylvanians access to high-quality hospital care.

HAP believes that beginning the process of improving Pennsylvania’s regulatory oversight of hospitals by focusing on several key priority areas will help foster innovation in meeting community health needs.I look forward to our continued conversations.


Andy Carter
President and Chief Executive Officer

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