Regulations:
6 Items That Will Determine Enforcement Sanction Levels
Published on Fri Sep 03, 2021
Quality of care is key.
If you get a condition-level deficiency on your next survey, you may have to pay the piper.
The Centers for Medicare & Medicaid Services sets out these factors surveyors will use “to determine which remedy or remedies to apply,” CMS says in the home health proposed rule for 2022:
- The extent to which the deficiencies pose Immediate Jeopardy to patient health and safety.
- The nature, incidence, manner, degree, and duration of the deficiencies or noncompliance.
- The presence of repeat condition-level deficiencies, the hospice’s compliance history in general, and specifically concerning the cited deficiencies, and any history of repeat deficiencies at any of the hospice’s additional locations.
- The extent to which the deficiencies are directly related to a failure to provide quality patient care.
- The extent to which the hospice is part of a larger organization with documented performance problems.
- Whether the deficiencies indicate a system-wide failure of providing quality care.
These factors “are consistent with the factors for HHA alternative sanctions,” CMS points out in the rule.