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CMS publishes revisions to State Operations Manual

CMS has published several transmittals that outline revisions made to the State Operations Manual that you should be aware of. Key updates include:

  • Revisions to State Operations Manual – Chapter 2 (Effective Date 6/10/16) – This revision clarifies guidance to surveyors regarding Exit Conferences at the end of survey for long term care facilities as well as other providers. In March, CMS issued S&C Ref: S&C 16-11-ALL, which provided guidance to surveyors to remind them that exit conferences are not mandatory, are meant to be informal, and that they should not give away too many details. What’s important to note here is that surveyors should not provide Scope/Severity of deficiencies unless there is an IJ finding. That’s because CMS is looking to strengthen survey processes, standards and training, including a supervisory review of surveyor findings before a 2567 is sent to the provider. These enhancements to the way deficiencies are cited means that there will also be increased enforcement activities. That means potentially more fines and more remedies coming your way as CMS standardizes the way the survey and enforcement processes are conducted across the country. Read Transmittal 154 for more information on Exit Conference procedures.
  • Revisions to State Operations Manual – Appendix P – Survey Protocol for Long Term Care Facilities (Effective Date 6/10/16) and Revisions to State Operations Manual – Appendix PP – Guidance to Surveyors for Long Term Care Facilities (Effective Date June 10, 2016) – In April, CMS issued S&C letter Ref: S&C: 16-15-NH, providing guidance to surveyors on revisions to F-329 and psychosocial harm related to the use of unnecessary medications. Revisions were made to help surveyors more easily identify how psychosocial harm can be caused by the use of unnecessary medications, but also includes language at a multitude of other F-tags to help surveyors determine if there were negative psychosocial outcomes. Read Transmittal 156 related to the Psychosocial Outcome Severity Guide in subsection E of Appendix PP. The information in Transmittal 157 includes interpretive guidance revisions to help surveyors determine psychosocial harm when assessing compliance with specific regulations.

Is your nursing facility preparing for survey? CMS Compliance Group can help. Contact us today at 631.692.4422 or via email to learn about our pre and post survey consulting services for nursing homes, including mock surveys, quality reviews, Plan of Correction/ Directed Plan development and implementation, Directed InService and other offerings.

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