Regulations:
Surveyors To Use 6 Factors When Setting CMP Rates, Other Sanctions
Published on Thu Jul 19, 2012
Immediate jeopardy determination will make the biggest difference.How will a surveyor decide you just need some training versus imposing punishing civil monetary penalties? And if you are subject to CMPs, how will the Centers for Medicare & Medicaid Services set them? All of these elements would play into the decision, CMS says in its 2013 HH PPS proposed rule:1. Whether the deficiencies pose immediate jeopardy to patient health and safety;2. The nature, incidence, degree, manner, and duration of the deficiencies or noncompliance3. The presence of repeat deficiencies, the HHA's compliance history in general, and specifically with reference to the cited deficiencies, and any history of repeat deficiencies at either the parent or branch location;4. Whether the deficiencies are directly related to a failure to provide quality patient care;5. Whether the HHA is part of a larger organization with documented performance problems;6. Whether the deficiencies indicate a system wide failure of [...]