Home Health & Hospice Week

Recert surveys are at the bottom of the list.

While a provider is never sure exactly when its number is up for surveys, you can get an idea of where you stand in line in Medicare’s new memo on the topic.

“States should resume normal survey activities according to guidance in the FY 2020 Mission & Priority Document, while prioritizing their survey backlog as follows (descending in priority),” the Centers for Medicare & Medicaid Services says in QSO-20-35-ALL:

1. Revisit surveys for past non-compliance that do not otherwise qualify for a desk review;
2. Complaint surveys triaged as non-Immediate Jeopardy level or higher that have not been completed;
3. Special Purpose Renal Dialysis Facilities (SPRDFs);
4. Initial surveys of new providers;
5. Past-due recertification surveys with a statutorily required survey interval (home health agencies and hospices must be surveyed every 36 months); and
6. Past-due recertification surveys without a statutorily required survey interval.

Desk review: If you had past noncompliance findings, but they were put on hold in the March 23 through May 31 period due to COVID-19, you may now have those citations resolved with a desk review, not requiring an onsite visit.

Exception: “Any unremoved IJs … still require an onsite revisit,” CMS says in the memo. Surveys with citations “at the IJ level, when the IJ finding has been verified as removed to a lower level of noncompliance, or corrected,” are OK for desk reviews, though, CMS clarifies.

Note: The nine-page memo is at www.cms.gov/files/document/qso-20-35-all.pdf.