Definition: According to HHS and CMS, medical staff is defined as a group of health care professionals, including physicians who are medical doctors or doctors of osteopathy at a minimum. All hospitals must maintain an organized medical staff with bylaws and a governing body.1
The medical staff may also include professionals other than physicians if the governing body approves them and the appointment does not conflict with state law.1 Other practitioners defined as physicians include Doctor of Dental Surgery, Doctor of Optometry, and Doctor of Podiatric Medicine. In 2012, CMS broadened the definition of medical staff to include nonphysician practitioners like pharmacists, nurse practitioners, and physician assistants.2
How it relates to medical homes/accountable care organizations: While the pharmacist’s role as a nonphysician practitioner is not well-defined in the Social Security Act 1861(r), the practice of granting nonphysician health care professionals medical staff privileges has pushed health care institutions to allow pharmacists to participate in collaborative practice agreements.2,3 Being part of the medical staff allows pharmacists in their organizations to perform advanced clinical functions within their scope of practice.2 Once appointed, pharmacists can also be part of the governing body and examine other individuals who wish to join the medical staff, make recommendations about the bylaws, etc. They can also undergo credentialing and privileging. Having a well-defined medical staff with appropriate credentialing and privileging for each discipline is key to providing optimal team-based care in medical homes and ensuring appropriate reimbursement.4
Organizations involved/oversight: Under HHS and CMS guidelines, each health institution’s governing body is allowed to define medical staff in accordance with state laws and each profession’s scope of practice.1
Resources:
- National Archives. Code of Federal Regulations 42 CFR 482.22. Updated September 30, 2019. Available at: eCFR :: 42 CFR 482.22 — Condition of participation: Medical staff.
- Engle JP, Dick TB, Bryant G, et al. Credentialing and privileging for clinical pharmacists. J Am Coll Clin Pharm. 2020; 3: 133–144. https://doi.org/10.1002/jac5.1201.
- SSA, ordp Definitions of services, institutions, etc., Act §1861. Available at: www.ssa.gov/OP_Home/ssact/title18/1861.htm. Accessed: July 17, 2024.
- Dawson C, Pham A, Shipman C, et al. Implementation and expansion of inpatient and ambulatory pharmacist credentialing and privileging at an academic medical center, AJHP. 2023;80 (12): 756–764, https://doi.org/10.1093/ajhp/zxad005.
Contributing authors:
Heather A. Johnson, PharmD, BCACP
Assistant Professor of Clinical Pharmacy and Family Medicine
Robert C. Byrd Health Sciences Center
West Virginia University