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Ftag of the Week – F865 QAPI Program/Plan, Disclosure/Good Faith Attempt (Part 2)

This week on the CMSCG Blog we are continuing our “Ftag of the Week” series on QAPI with Part 2 of F865 QAPI Program/Plan, Disclosure/Good Faith Attempt. In last week’s post, we reviewed the scope and design of a QAPI Program, the regulatory expectation that QAPI is continuous and ongoing, and also reviewed what will happen during survey related to QAPI. So, how does a facility ensure that all these things are happening and make proactive attempts to correct identified issues? Let’s find out.

Governance and Leadership

The governing body and/or executive leadership team are responsible for the facility’s QAPI program (view CMSCG’s Ftag of the Week on F837 Governing Body here). They are responsible for ensuring that the QAPI Program:

Good Faith Attempts

The regulation at F865 clearly discusses the idea of “good faith attempts to correct.” The Interpretive Guidance (IG) states that if a facility has identified and made a good faith attempt (through its QAA Committee) to correct an issue that has been identified by surveyors on the current survey, the facility will not be cited for QAA. However, the facility can still be cited under other relevant tags. The expectation is that the surveyor will determine if:

Other Things to be Aware of

In closing, if you have not wrapped your arms around the need to be compliant with all aspects of this regulation put some time aside for you and your team to review your QAPI Program / Plan and how you can demonstrate compliance.

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