Can the same individuals who make up the governing body and/or the same individuals who make up the medical staff be responsible for more than one hospital?
Yes, as long as the responsibilities for each hospital’s governing body and medical staff are performed independent of carrying out responsibilities for another hospital, and there is evidence of such. For example, the same set of individuals may function as the governing body or medical staff for more than one hospital, but they must convene themselves separately as each hospital’s governing body or medical staff in order to carry out their responsibilities for each separately certified hospital. The separation does not have to be by place, but by time – in other words, the same individuals can meet in one place, convene themselves as the governing body of Hospital A, conclude their business, and then convene themselves as the governing body of Hospital B, etc. Each meeting must have its own set of minutes, etc. Further, with respect to the medical staff, there needs to be a separate privileging process for each hospital, even though the same physicians may practice at both hospitals.
