At its September 21, 2000, meeting, the New York State Hospital Review and Planning Council (SHRPC) Codes and Regulations Committee voted to recommend the adoption of revisions to the part-time clinic regulations that were adopted on an emergency basis at SHRPC's August 3, 2000, meeting and that became effective on August 15, 2000. The new regulations prohibit part-time clinics from being operated in certain locations (including private physicians' offices) and require that they be operated in proximity to the sponsoring facility's main site. The proposed changes would permit part-time clinics to be operated in private physicians' offices if the office space is leased for a defined period of time and used on a regular basis to provide low-risk services. The proposed revisions also clarify that appeals of disapprovals of part-time clinic applications would be made to SHRPC.

GNYHA Comments: GNYHA had provided extensive comments to SHRPC prior to the adoption of the regulations in August. At the September 21, 2000, SHRPC Codes and Regulations Committee meeting, GNYHA commented in support of the proposed regulatory revisions that would permit part-time clinics to be operated in private physicians' offices. GNYHA also commented that the prohibition on operating part-time clinics in certain other locations (for example, adult homes and intermediate care facilities) should also be removed and that part-time clinics that are dually licensed by the NYS Department of Health and other agencies should be permitted to continue to operate. In addition, GNYHA commented that the list of acceptable services put forth in the regulations should not be considered all-inclusive, but examples of appropriate services.

New Prior Approval Process: The regulations also establish a new prior approval process by which all existing and proposed clinics are approved to provide services. Future operators are required to submit applications at least 45 days prior to opening the site. In order to continue operating, current operators are required to submit applications to DOH by November 13, 2000.

Member Briefing: GNYHA is holding a member briefing session on the regulations on October 13, 2000; call Barbara Marino at GNYHA to register. If you have any questions about the regulations, the application process, or the briefing, please call Doris R. Varlese at GNYHA.