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CMS Issues New Nursing Home Survey QSO Memo

Yesterday afternoon, the Centers for Medicare & Medicaid Services (CMS) made several announcements about the Agency’s shift in focus to Infection Control in healthcare facilities due to concerns over COVID-19. In this CMSCG Blog, we will look at the QSO Memo related to surveys.

Surveys

In a March 4, 2020 CMS QSO Memo, “Suspension of Survey Activities,” the Agency states that non-emergency inspections are being suspended. Surveys that are statutorily-required will continued in nursing homes across the country, but CMS will be shifting the focus of its work to infection control and other “emergent issues,” including focusing on the most serious health and safety threats, such as a abuse and neglect.

A priority of how surveys will be conducted is as follows:

  • Immediate Jeopardy complaints and allegations of abuse and neglect will be a priority.
  • Next, complaints related to Infection Control concerns will be prioritized, including for facilities that have respiratory illnesses or potential COVID-19 issues.
  • Statutorily-required recertification surveys will continue and will prioritized after IJ complaints and Infection Control-related complaints. This includes all nursing home, home health, hospice and ICF/IID providers.
  • Revisits to resolve current enforcement actions in place will be the next priority.
  • Initial certifications
  • Surveys of facilities or hospitals that have a history of Infection Control deficiencies at an Immediate Jeopardy-level in the last three years
  • Surveys of facilities, hospitals and dialysis centers that have a history of Infection Control deficiencies at any Scope/Severity lower than an Immediate Jeopardy level.

As CMSCG has mentioned continuously, F880 Infection Prevention and Control continues to be one of the most frequently cited Ftags during survey. This emphasis on Infection Control by the regulatory bodies will sharpen the focus on Infection Control practices and providers would be well-served to listen to CMS’s “call to action” to ensure that healthcare facilities are implementing their Infection Control procedures as regulatorily mandated. The LTCSP Infection Prevention, Control & Immunizations investigative protocol is included as an addendum in the QSO Memo. Nursing Home Providers should use this tool and assess their current practice to identify potential Infection Control and Environmental issues.

CMS has created a Coronavirus webpage on its site and will post updates to State Surveyors and Accrediting Organizations on it. This webpage can be found here.

The QSO Memo also includes information for State Agencies/Accrediting Organizations on protocols for coordination and investigation of facilities that have suspected or actual COVID-19 cases.

View the March 4, 2020 QSO Memo, “Suspension of Survey Activities” (Ref: QSO-20-12-ALL).

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