The Centers for Medicare & Medicaid Services (CMS) issued an S&C memo to all providers regarding new guidance for how plans of correction are to be formatted. The following list of required elements must be included for an acceptable Plan of Correction (PoC) or credible Allegation of Compliance (AoC):
- The plan for correcting the specific deficiency. The plan should address the processes that lead to the deficiency cited.
- The procedure for implementing the acceptable PoC for the specific deficiency cited
- The monitoring procedure that will ensure the PoC is effective and that the specific deficiency remains corrected and/or in compliance with regulatory requirements.
- The title of the person who is responsible for implementing the acceptable PoC.
Additionally, since the CMS Form 2567 and the PoC/AoC are documents released to the public, providers must omit any Protected Health Information (PHI) or Privacy Act Information. If protected information is included in the PoC, the SA will notify the provider to obtain an amended version.
For LTC facilities, the requirement for posting survey results requires that facilities post the most recent 2567 and any PoC in effective. If the facility chooses to attach its PoC to the first page of the 2567, it must post the PoC in addition to the publicly available 2567 Form.
Read the June 16, 2017 CMS S&C memo, “New Guidance for Formatting of the Plans of Correction” (Ref: S&C: 17-34-ALL).