In a September 11, 2015 CMS S&C letter, the Agency updates the guidelines for the Home Health Agency (HHA) Survey Protocols. CMS provides training on the use of these protocols that are used to assist HHA surveyors with determining whether a Condition-level deficiency should be issued. The letter notes that the trainings used to emphasize that the phrase “consider citing the condition” implied that the surveyor “should” cite the condition, but that the training focus has been revised. Now the training indicates that surveyors “may” consider citing a Condition when the regulation provides indication, but it does not mean “should.” This allows the surveyors more freedom to use their judgement as to whether a deficiency should be issued or not.
Read CMS S&C Letter “Home Health Agency (HHA) Survey Protocol Training Item Revised” (Ref: S&C 15-52-HHA).
Also note that CMS issued an S&C letter on August 28, 2015 to Home Health Agencies regarding an update to Section 2185 of the SOM regarding change of address and notification of Medicare Administrative Contractors (MACs).