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CMS Letter: Survey & Certification Changes Due to Sequestration

In its April 5, 2013 letter “FY2013: Sequestration Adjustments for Survey & Certification (S&C),” CMS announced several changes to be made regarding the survey process in regards to reduce expenses. The following areas will see changes in the survey and certification process:

  • Providers that Elect to Decline Medicare Assignment
  • IPPS Exclusions or Addition of Locations
  • Revisit Surveys
    • State Agencies will provide information to affected facilities that revisits may take longer than usual.
    • CMS RO approval must be obtained before conducting a second revisit for compliance and CMS CO approval must be obtained before conducting third or fourth revisits.
  • Critical Access Hospital (CAH) Conversions
  • Special Focus Facility (SFF) Nursing Homes
    • State Agencies must schedule a final “last chance” onsite survey with nursing homes that have been designated Special Focus Facilities for more than 18 months and have failed to improve. This survey may be scheduled at the same time as the next scheduled survey or occur before that.
      • CMS RO approval may be obtained to issue a Medicare termination notice if improvement is not shown that will enhance resident quality of care or safety.
    • For nursing homes that have been on the Special Focus Facility list for 12 months but less than 18 months, State Agencies must review their progress and discuss with CMS staff the status an action plan going forward.
    • When a current SFF has graduated from the list after showing improvement or has been terminated from Medicare, a new facility should not be selected to be added to the list unless the CMS CO directs the State Agency to do so.
  • Home Health Targeted Surveys
    • All Tier II targeted surveys of home health agencies identified by CMS as being poor performers should be discontinued unless CMS directs the State Agencies to do otherwise.
    • No HHA should go without having an onsite recertification survey for more than 3 years.
  • Life Safety Code (LSC) in Nursing Homes
    • CMS issued a separate letter on April 5, 2013 related to the August 13, 2013 requirement that nursing homes be fully sprinklered, “Life Safety Code (LSC) Short Form Survey for Nursing Homes – Limited Option.”
    • A Short Form survey is being made available for State surveyors to use for assessing compliance with key LSC requirements for nursing homes that have a strong, consistent track record of compliance with these requirements in the past. To qualify, these nursing homes must be fully 100% sprinklered.
    • If a State chooses to use this type of assessment, some information will need to be reported to the CMS CO so it can evaluate how effective this option has been.
    • The Life Safety Code Short Form available prior to 2006 was discontinued.
  • Organ Transplant Program Surveys
  • Hospital Complaint Investigations

If your nursing home has been placed on the Special Focus Facility list, we can help with major issues, systems assessments, retraining your staff and monitoring for compliance. This type of assessment is essential for facilities that will be given the “last chance” onsite survey before termination from Medicare, but all SFFs can benefit from these services to help them graduate from the list. We can also complete Life Safety engineering/ environmental consultation to help ensure your facility will pass a LSC inspection. Learn more about CMS Compliance Group’s project-based services.