Following are the links to two (2) new Centers for Medicare and Medicaid Services (CMS) survey and certification letters:
I.
FY2013 Sequestration Adjustments for Survey & Certification (S&C) 4/05/13
This Letter describes the policy or operational adjustments CMS is making to accommodate the federal budget reductions resulting from sequestration [effective 3/1/13] that impact State operations / State survey agency (SA) functions and that “…are intended to help States accomplish priority work within the reduced budget.”
· “The overall FY’ 13 S&C Medicare budget is reduced by 5% from the FY2012 level, amounting to approximately $19 million.” Of the total reduction, CMS expects expects State allocations to be reduced by 2.5% – 3% from the FY ‘12 national budget level. The remaining reduction will be taken from CMS Central Office (CO) functions, contractual services, and one-time budget items.· States are expected to adhere closely to CMS priorities in conducting all survey and certification work.
· CMS will make adjustments to the State Performance Standards System (SPSS) to accommodate the changes described and to reinforce strict adherence to the CMS workload prioritization.
· CMS states it is “…protecting SA ability to continue onsite complaint investigations and surveys of existing providers, while reducing expenses, suspending additions to the workload, reducing time spent on lower risk areas, and reducing the CMS CO services.”
· Separate communications will be sent to States regarding specific allocation amounts for each State.
The policy and operational adjustments State Survey Agency Directors are instructed to implement immediately include:
Providers that Elect to Decline Medicare Assignment
· All entities that acquire providers / plan to acquire another provider and to decline [current] assignment of Medicare certification “…(thereby resulting in termination of the existing provider agreement)”, must be informed “…there may be longer wait-times for the onsite surveys and certification work necessary period before an initial certification survey will be conducted and before Medicare participation may therefore be resumed, regardless of who might conduct the survey (State, accrediting organization, or CMS).”
IPPS Exclusions or Addition of Locations: Exclusions from the Inpatient Prospective Payment System (IPPS), or requests to add locations on the part of an existing provider
· Entities that inquire about adding locations/services for Medicare-certified providers are to be informed “there may be longer wait-times for any onsite surveys or certification work that may be necessary.· This includes additional branches or secondary locations to an existing home health agency, hospice, hospice inpatient units, Outpatient Physical Therapy extension sites, Swing Beds, or end stage renal disease services.”
Revisit Surveys
a. CMS Regional Office (RO) approval must be obtained prior to a second onsite revisit after a first revisit found the
provider had still not achieved substantial compliance.
b. CMS Central Office (CO) approval must be obtained prior to a third or fourth onsite revisit (when a 3rd or 4th
revisit is permitted by CMS policy) when the prior revisit found the provider had not achieved substantial
compliance. Existing protocols already require consultation /approval from CMS for some revisits (e.g., 3rd and
4th), “…so the effect of this change is simply to change the thresholds at which the consultation occurs.”
c. Affected providers are to be informed there may be longer wait times for revisits.
Special Focus Facility (SFF) Nursing Homes
a. “Last chance” onsite surveys are to be scheduled for facilities on the SFF list for more than 18 months that have
failed to improve.
o This survey may coincide with the next planned onsite survey, “…or be advanced in accordance with the extent to which State monitoring continues to indicate lack of significant progress.”
o After discussion with the CMS RO, “…a Medicare termination notice may be issued if the onsite survey does not reveal appropriate improvement or unless there is a major new development that CMS concludes is very likely to eventuate in timely and enduring improvement…”
b. The progress of all other SFF facilities on the list for more than 12 months is to be reviewed. “CMS staff will
discuss with the SA the status of each facility and plan further action.”
c. Until further notice, no replacement SFFs will be identified when a SFF is terminated from Medicare participation
or is graduated, unless otherwise directed by the CMS RO.
· CMS states, “The effect of this adjustment will be to (a) speed final resolution (preferably substantial improvement)…where serious problems have persisted for a considerable time, and (b) continue the SFF initiative…, but at a temporarily reduced number of facilities.”
Home Health Targeted Surveys
· All further Tier II targeted surveys of home health agencies (HHAs) that CMS has identified to SAs has having the lowest performance will be discontinued unless otherwise directed by CMS.· SAs are to continue to ensure that no HHA goes more than 3 years without an onsite recertification survey.
Life Safety Code (LSC)in Nursing Homes
a. CMS is providing, at State option, a Short Form survey that may be used to assess compliance with key life-safety
code requirements for nursing homes “…CMS determines have a consistently good track record of LSC compliance…, provided the nursing home is also [100%] fully-sprinklered.” CMS will provide a list to each SA of facilities that may qualify for the Short Form survey.
b. States electing this option will be required to provide basic information to CMS CO for the purpose of evaluation.
c. Certain targeting and quality controls will apply to the use of the Short Form survey. [S&C Memorandum
13-22-NH (4/5/13) offers more specific details – see below].
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II.
Life Safety Code (LSC) Short Form Survey for Nursing Homes – Limited Option (4/05/13)
CMS’ stated intent for this procedure is to “allow surveyors to spend more time with facilities whose life safety code compliance poses greater risk to residents, and less time with those above-average facilities where life-safety code compliance is superior.” Improving targeting of surveyor time is important to “(a) meet the resource limitations of the recent sequester-required budget reductions…”, (b) respond to the challenge of enforcing the 8/13/13, deadline for all nursing homes to be fully sprinklered, and “…(c) ensure that Medicare and Medicaid funds are used in the most efficient and effective manner.”
State Option
· CMS will permit States - at States’ option - to implement a Short Form Fire Safety Survey for a limited number of specified facilities that have demonstrated superior compliance with life safety code requirements and are fully sprinklered.
· These facilities will be identified on a confidential list that, beginning in FY ‘13 and at the beginning of each year thereafter, CMS will make available to the respective State Survey Agencies (SAs).
· Only facilities that are considered fully sprinklered, do not have any significant waivers of LSC requirements, and are not certified by the use of the Fire Safety Evaluation System (FSES) will be considered for use of the short form survey (CMS is not eliminating the use of the longer LSC survey process or the FSES in implementing this Short Form.)
CMS Selection Criteria and Process
· For the selected nursing homes, the Short Form may be used to collect data on a specific set of K tags.· These identified K tags will give a core indication of the facility fire safety status. If initial survey findings indicate there are serious problems, the survey must be expanded to cover additional K tags.
· The Short Form already contains more than the initial set of K tags, so the survey may easily be expanded while the survey team is onsite, or a full survey may be scheduled.
To be eligible for the Short Form process the facility must:
o Be fully sprinklered;
o Generally not have any waivers or use the Fire Safety Evaluation System – Health Care (FSES/HC) to be certified;
o Have not been cited for K0062 Sprinkler Maintenance, K0054 Smoke Detector Maintenance, K0050 Fire Drills, K0104 Smoke Barriers and 0051 Fire Alarms in the last two years.
o Not have more than 2 survey cycles since the last Long Form survey was conducted.
· CMS advises these criteria may be subsequently modified based on the results of LSC surveys over time. · Short Form surveys might be completed by health surveyors who have participated in a webinar in which specific K tags are reviewed; or by surveyors who ordinarily complete fire safety surveys (such as State Fire Marshals or other Health Department staff who may conduct LSC surveys on a regular basis).
Attachment A
The Letter includes Attachment A: Life Safety Code – Targeted LSC Short Form - Special Survey Instructions
· The process uses the existing Short Form 2786R (6/2007 edition).· Use of the existing form will expedite the process as it is already available and is part of the current data system.
· The 2786R has been used in the past as a screening tool to determine if a more detailed LSC survey is required.
· The K tags selected for SF review are concentrated in the maintenance of fire protection systems in the facility, fire drills for staff, means of egress availability and emergency electrical power where installed.
Key K Tags for the Short Form Survey
· The following K tags are proposed to be reviewed by surveyors on-site:
o K38 - Exit access:
o K39 - Exit corridor width
o K47 - Exit signs operational:
o K50 - Fire drills:
o K52 - Fire alarm system properly maintained
o K62 - Automatic sprinkler system properly maintained
o K72 - Means of egress unobstructed by furnishings and decorations
o K144 - Emergency generator properly maintained
o K211 - Alcohol based hand rubs properly used
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