Should the medical staff be departmentalized?
CMS’s CoPs state that medical staff bylaws must “describe the organization of the medical staff” (42 CFR § 482.22(c)). One of the key structural questions a medical staff must ponder is whether to organize itself into clinical departments. Although there is no regulatory mandate to do so, medical staffs have historically organized themselves around departments based on specialty. This was initially a relatively simple structure composed of a few key departments representing major specialties, including medicine, surgery, OB-GYN, and, occasionally, pediatrics.
Many clinical departments are looking for less burdensome ways to fulfill their responsibilities more effectively. Physicians have less time than ever to devote to medical staff citizenship responsibilities, especially as many are spending less time at the hospital to grow their private practices, satisfy the productivity demands of their employer, or pursue other professional activities. Many medical staffs have found that their work is best accomplished by a small cadre of well-trained leaders who can represent the broad interests of physicians and carry out medical staff work efficiently. Downsizing the medical staff bureaucratic structure facilitates this kind of transformation and, as a result, many medical staffs are consolidating their departments, with no detriment to the staff’s ability to carry out critical functions. This is compliant with regulations and standards as long as the medical staff accomplishes its delegated functions.
In recent years, more and more medical staffs have chosen to become non-departmentalized. They are organized to achieve their work through established or ad hoc committees. It is important to check with state hospital regulations to make sure that an option to become non-departmentalized is compliant. A non-departmental approach makes particular sense where a hospital has well-developed operational service lines. If both medical staff clinical departments and hospital service lines exist side by side, it is especially important to clearly define the accountabilities of each. It is also important to provide clarity around the respective roles and responsibilities of chairs and medical directors for each.