Navigating New CMS Conditions of Participation with WrightCare Consulting

Janae Wright
May 7
3 min read

On April 30, 2025, the Centers for Medicare & Medicaid Services (CMS) announced significant updates to the Conditions of Participation (CoPs) for hospitals and critical access hospitals (CAHs), effective July 1, 2025. These changes, outlined in the CY 25 Outpatient Prospective Payment Final Rule (89 FR 93912, amended January 13, 2025, 90 FR 2631), introduce new requirements for discharge planning, transfer protocols, and emergency services readiness. As healthcare organizations prepare to comply, WrightCare Consulting is here to guide you through these regulatory updates with tailored solutions to ensure compliance and operational excellence.

Key Updates to CMS Conditions of Participation

Hospitals

Discharge Planning (§ 482.43)Hospitals must establish written policies and procedures for transferring patients to the appropriate level of care, including to other hospitals, as needed. Annual training for relevant staff on these protocols is mandatory.
Emergency Services (§ 482.55)Hospitals must ensure adequate provisions and protocols to meet emergency patient needs, aligned with nationally recognized, evidence-based guidelines. Requirements include:
- Maintaining readily available equipment, supplies, drugs, blood products, and biologicals for life-saving procedures.
- Implementing a call-in system for each emergency treatment area.
- Providing annual staff training, with documented evidence of completion and demonstrated staff knowledge.

Critical Access Hospitals (§ 485.618)

CAHs must also adopt protocols and provisions for emergency services readiness, consistent with evidence-based guidelines. This includes:

Annual staff training with documented completion and knowledge demonstration.
Using findings from the Quality Assessment and Performance Improvement (QAPI) program to inform ongoing training needs and updates.

Challenges for Healthcare Organizations

The new CoPs require robust policy development, staff training programs, and documentation systems to demonstrate compliance. Without interpretive guidance from CMS, organizations may struggle to align their processes with these standards. Non-compliance could jeopardize accreditation, reimbursement, and patient safety.

How WrightCare Consulting Can Help

At WrightCare Consulting, we specialize in helping healthcare organizations navigate complex regulatory landscapes. Our team of experts offers comprehensive services to ensure your hospital or CAH meets the new CMS CoPs with confidence:

Policy Development: We work with your leadership to create customized policies and procedures for discharge planning, patient transfers, and emergency services that align with CMS requirements and your facility’s unique needs.
Staff Training Programs: Our tailored training modules ensure your staff are well-versed in the new protocols. We provide engaging, evidence-based training sessions and assist with documentation to demonstrate compliance.
Compliance Audits and Gap Analysis: WrightCare conducts thorough assessments to identify gaps in your current processes. We provide actionable recommendations to bridge these gaps and ensure readiness for CMS surveys.
QAPI Integration for CAHs: For CAHs, we help integrate QAPI findings into your training programs, ensuring continuous improvement and compliance with § 485.641.
Ongoing Support and Education: Our team stays ahead of regulatory changes, providing updates and resources to keep your organization compliant. We also offer webinars and workshops.

Why Choose WrightCare Consulting?

Expertise: Our consultants have deep knowledge of CMS regulations and accreditation standards.
Customized Solutions: We tailor our services to fit your organization’s size, scope, and operational complexity.
Proven Results: We’ve helped numerous hospitals and CAHs achieve compliance and improve patient outcomes.
Proactive Approach: We anticipate challenges and provide solutions before they become issues.

Take the Next Step

The July 1, 2025, deadline is approaching, and now is the time to act. WrightCare Consulting is your trusted partner in achieving compliance with the new CMS CoPs.

Contact us today at info@wrightcareconsulting.org or 806-680-4172 or visit wrightcareconsulting.org to schedule a consultation. Let us help you turn regulatory challenges into opportunities for excellence.

WrightCare Consulting: Your Partner in Healthcare Compliance and Quality.