Home Health & Hospice Week

Routine surveys are back on deck.

Back in March, CMS Administrator Seema Verma announced that regular Medicare surveys would go by the wayside. Now you have an idea of what’s taking their place.

In a March 23 release, the Centers for Medicare & Medicaid Services said surveyors would not conduct standard inspections of providers including home health agencies and hospices (see Eli’s HCW, Vol. XXIX, No. 11). Surveyors still would conduct complaint inspections related to Immediate Jeopardy concerns and targeted infection control inspections, CMS continued.

Now in a June 1 survey memo, CMS says it is “providing guidance for the limited resumption of routine survey activities” and “enhancing the penalties for non-compliance with infection control to provide greater accountability and consequence.”

While the survey memo talks in detail about nursing home surveys, “the memo addresses all provider types,” the National Association for Home Care & Hospice stresses. In transitioning “to more routine oversight and survey activities, once a state has entered Phase 3 of the Nursing Homes Re-opening guidance,” they “are authorized to expand beyond the current survey prioritization (Immediate Jeopardy, Focused Infection Control, and Initial Certification surveys) to perform (for all provider and supplier types): Complaint investigations that are triaged as Non-Immediate Jeopardy-High; Revisit surveys of any facility with removed Immediate Jeopardy (but still out of compliance); [and] Special Focus Facility and Special Focus Facility Candidate recertification surveys” (emphasis added).

“When determining the order in which to schedule more routine surveys, States should prioritize providers based on those with a history of noncompliance, or allegations of noncom­pliance, with the below items: Abuse or neglect; Infection control; Violations of transfer or discharge requirements; Insufficient staffing or competency; or Other quality of care issues (e.g., falls, pressure ulcers, etc.),” the memo continues.

“Accrediting organizations may resume normal survey activities based on state reopening criteria,” the memo continues.

The six-page memo is at www.cms.gov/files/document/qso-20-31-all.pdf.