RSSAll Entries in the "CMS" Category

Joint Commission updates EM standards to match CMS

In response to CMS’ final emergency preparedness rule issued earlier this month, The Joint Commission announced revisions to its emergency management (EM) standards. CMS is expected to approve the updated standards before they go into effect on November 15.

Accredited organizations can access the proposed drafts on their Joint Commission Connect™ extranet site, with more information on the way.

The Joint Commission’s standards come with new Elements of Performance on the following topics:

•    Continuity of operations and succession plans
•    Documentation of collaboration with local, tribal, regional, state and federal emergency management officials
•    Contact information on volunteers and tribal groups
•    Annual training of all new or existing staff, contractors, and volunteers
•    Integrated healthcare systems
•    Transplant hospitals

Several of the new requirements merely provide more specifics on what The Joint Commission already expects. This includes including documentation for existing practices and annual training for staff.

CMS first announced the emergency preparedness CoPs in September 2016, compelling hospitals to communicate and coordinate their emergency plans with other hospitals and government agencies.

They also require regular emergency preparedness training with staff and disaster contingency planning. CMS published the final version of the new Appendix Z of Medicare’s State Operations Manual online, and state surveyors will use newly created E-tags to score deficiencies and expectations set in it.

 

CMS temporarily suspends some Medicare requirements for hurricane-stricken hospitals

Joint Commission also suspending surveys of hurricane affect hospitals temporarily

CMS Administrator Seema Verma announced the agency is temporarily suspending certain Medicare requirements for healthcare providers assisting with Hurricane Irma recovery efforts in Florida, Puerto Rico, and the U.S. Virgin Islands. The Joint Commission also announced that it would be suspending survey activities in the affected areas for the time being.

At the moment, CMS is waiving the following enrollment requirements:
•    Payment of the application fee
•    Fingerprint-based criminal background checks
•    Site visits
•    In-state licensure requirements

“CMS is dedicated to making it as easy as possible for the individuals and families impacted by Hurricane Irma to access medical care during this difficult time,” said Verma. “There are healthcare providers and suppliers in the aftermath of the hurricane that are ready and willing to help. CMS has established a hotline for providers and temporarily suspended certain Medicare requirements so that these healthcare professionals can provide services to those in need.”

The toll-free hotline she’s referring to is for non-certified Medicare Part B providers and other practitioners so they can enroll in federal health programs and receive temporary Medicare billing privileges. First Cost Service Option, a Medicare Administrative Contractor, will work to assist providers in these areas to temporarily enroll healthcare providers. The number is 855-247-8428, and it’s in service between 8 a.m. and 6 p.m. ET

Starting September 18, 2017, providers will be able to initiate temporary Medicare billing privileges over the phone and on the same day. In addition, CMS is:

•    Allowing providers not currently enrolled to initiate temporary billing privileges by providing limited information. This information includes (but isn’t limited), National Provider Identifier (NPI), Social Security Number (SSN) or a business Employer Identification Number taxpayer identification numbers (SSN/EIN/TIN), and valid in-state or out-of-state licensure.
•    Temporarily ceasing revalidation efforts for Medicare providers in areas directly impacted by Hurricane Irma.
•    Waiving the practice location reporting requirements
•    Not taking administrative actions on providers who fail to notify them about their temporary practice location. This temporary process will remain in effect from September 7 until the disaster designation is lifted. After that, it must be reported through appropriate channels.

“CMS will continue to work with all states and geographic areas in the path of hurricanes Irma and Harvey,” according to the press release. “The agency continues to update its emergency page (www.cms.gov/emergency) with important information for state and local officials, providers, healthcare facilities, suppliers and the public.”

To read previous updates regarding HHS activities related to Hurricane Irma and Hurricane Harvey, please visit https://www.hhs.gov/about/news/hurricane-response/index.html.

Crucial accreditation deadlines on the horizon for pain management and emergency preparedness

Time is running out to meet the new emergency management (EM) Conditions of Participation (CoP) and The Joint Commission’s revised pain management standards. The EM Interpretive Guidelines go into effect on November 15 while the pain management standards go into effect January 1.

Emergency management

The new EM CoPs fill gaps CMS’ previous regulations by compelling hospitals to communicate and coordinate their emergency plans with other healthcare organizations and government agencies. They also require regular emergency preparedness training with staff and disaster contingency planning.

Steve MacArthur, a safety consultant at The Greeley Company, pointed out that a lot of the new requirements include things that hospitals should have already been doing.

“While this rule is new to the ‘marketplace,’ there are really no new concepts contained therein,” he says. “This may provide some guidance for CMS surveyors as they drill down on organizational preparedness activities. But none of this is groundbreaking or in any way representative of a change in how hospitals have done, and will continue to do, business. [It’s] just another set of official ‘eyes’ looking through the compliance microscope.”

Pain management

The Joint Commission prepublished its new pain management standards back in June. The accreditor said it used the revision to address disparities between its standards and what the literature recommended. Some of the changes include:

•    Enabling clinician access to prescription drug monitoring program databases

•    Performance improvement activities focusing on pain assessment and management to increase the safety and quality for patients

•    Identifying the leader or leadership team responsible for pain management and safe opioid prescribing

•    Involving patients in developing their treatment plans and setting realistic expectations and measurable goals

•    Identifying and monitoring high-risk patients as a way to promote safe opioid use

Facilities should assign teams to research best practices in pain management, get the medical staff working on revising protocols and deter¬mining how to gather data on pain management effectiveness, and alert your information technology and electronic health records experts that they will be needed.

The annual fire and smoke door testing requirements will also be due by January 2018.

Fire and smoke: CMS clarifies which doors must be inspected annually

After pushback, federal officials backed away from their claim that smoke barrier doors must be inspected and tested annually.

More than three weeks after a well-publicized compliance deadline passed, CMS announced Friday that the deadline would be pushed back nearly six months, giving facilities until New Year’s Day 2018 to comply with an annual testing requirement for certain doors.

David Wright, director of the CMS Survey and Certification Group, made the announcement in a memo to state survey agency directors. He acknowledged that there had been a fair amount of confusion concerning the change, and he offered some pretty consequential clarifications that could affect whether the new requirement applies to your facility at all.

“[C]onsidering the level of reported misunderstanding of this requirement, CMS has extended the compliance date for this requirement by six months,” Wright wrote.

Within the National Fire Protection Association’s (NFPA) 2012 Life Safety Code® (LSC), which CMS adopted last year, there is a requirement that fire doors and smoke barrier doors be tested annually. Officials with CMS had taken the position that the new requirement applies to healthcare occupancies; that position, however, was met with pushback.

A petition objecting to the CMS position was discussed at length in June by members of the NFPA Healthcare Interpretations Task Force (HITF), says Brad Keyes, CHSP, owner of Keyes Life Safety Compliance. That petition objected to the notion that the LSC specifically requires annual inspections of smoke barrier doors in healthcare occupancies.

“The HITF members did discuss the issue and agreed that healthcare occupancies were exempt from complying with section 7.2.1.15.2 … because the healthcare occupancies did not specifically require compliance with that section,” Keyes says in an email.

The committee decided to table its decision on the matter to give CMS an opportunity to review its position, as it did, Keyes says.

“I am pleased that the system worked in favor for the many hospitals that are certified by the Federal agency,” he adds.

Although the LSC does include provisions requiring annual inspections of smoke barrier doors and fire doors alike, section 7.2.1.15.1 states that these standards apply only where required by Chapters 11–43. Since the chapters governing healthcare occupancies make no direct reference to Section 7.2.1.15.1, the door inspection provisions do not apply to healthcare occupancies, Wright acknowledged in his memo.

Based on that conclusion, Wright spells out a few key takeaways:

  1. Fire doors. In healthcare occupancies, all fire door assemblies must be inspected and tested annually in healthcare occupancies, based on section 8.3.3.1 of the 2012 LSC, which applies to all occupancies.
  2. Smoke barrier doors. Non-rated doors (including smoke barrier doors and corridor doors to patient care rooms) aren’t subject to the annual inspection and testing requirements, but they “should be routinely inspected as part of the facility maintenance program.”
  3. Deadline. The compliance deadline has been pushed back from July 6, 2017, to January 1, 2018.
  4. Citations. Any LSC deficiencies related to annual fire door inspections should be cited under K211—Means of Egress—General.

But what if a healthcare organization was already cited at some point during the three-week gap between the original compliance date and the clarifying memo (July 6–28) for a failure to conduct an annual test of its smoke doors? Multiple CMS representatives did not respond to requests for an answer. Keyes says CMS has been a stickler in the past, holding that a finding cannot be removed once it is written on a survey report.

“There was an accreditation organization [AO] that used to allow findings to be removed from their survey report if the hospital could demonstrate compliance at the time of the survey,” Keyes says. “CMS has said that the AOs may no longer remove findings, even if the hospital was compliant at the time of the survey.”

The Joint Commission stated in the July edition of Perspectives that it requires annual testing for fire door and smoke door assemblies alike, despite acknowledging that the healthcare occupancy chapters don’t cite section 7.2.1.15 specifically. (To support the requirement, The Joint Commission noted that Section 18/19.2.2.2.1 references section 7.2.1, and cited a belief that the annual tests are beneficial.)

Keyes adds a word of caution: “The AOs are not locked into complying with everything CMS says or does. The AOs may have standards that exceed what CMS requires.”

That means the guidance in Wright’s memo might not trickle down to the AOs and state agencies that conduct surveys at your facilities, especially considering how widely advertised the original compliance date has been.

“So, I suspect many of the AOs will keep the start date at July 5, 2017, since they are already enforcing that,” Keyes says.

With that in mind, he recommends that all healthcare facilities have their fire doors tested as soon as possible, rather than waiting until the new deadline—because another authority having jurisdiction might keep to the stricter timeline.

CMS withdraws proposal to have AOs post survey reports online

A proposal by CMS to have accrediting organizations (AOs) post the details of survey reports online was withdrawn by the agency, not because of negative comments — although there were plenty — but because, well, it might be prohibited under federal law.

CMS first made the proposal in April, tucking it into the latter pages of the always-long proposed on changes to the Inpatient Prospective Payment System (IPPS) for the upcoming fiscal year.

The proposal was to have AOs post final survey reports online within 90 days that the same information is available to the hospital or other health care organization, including details of all initial and recertification surveys at that provider in the prior three years, as well as the accepted plans of correction (PoCs).

AOs now post only whether an organization is accredited or not, and do not make details of findings public.

CMS argued its proposal was to promote transparency in health care, and noted that it posts its own  survey reports online. But critics responded that the CMS reports are made available in a hard-to-read spreadsheet and that the federal agency was responsible for far fewer surveys at health care organizations that were often surveyed only after a complaint (IJC 5/1/17).

In public comments to CMS concerning the proposal, The Joint Commission said that requiring survey details be made public would have “chilling effect” on efforts to raise standards of quality. Dr. Mark R. Chassin, president and CEO of The Joint Commission, wrote: “There will be a race to the bottom on quality as health care organizations seek out oversight bodies that will report on the least number of standards comparable to the Medicare requirements. This may also lead to a growth in non-accredited facilities that will then be surveyed at taxpayer expense and with fewer oversight visits.”

Other groups similarly weighed in against the proposal, and offered alternatives. In the end though, it was shot down because it might potentially be prohibited.

In the IPPS final rule published Aug. 2, CMS noted that its proposal included revising the federal regulations overseeing Medicare to incorporate the requirement for AOs to post report details publically.

“Section 1865(b) of the Act prohibits CMS from disclosing survey reports or compelling the AOs to disclose their reports themselves. The suggestion by CMS to have the AOs post their survey reports may appear as if CMS was attempting to circumvent the provision of section 1865(b) of the Act. Therefore, this provision is effectively being withdrawn.” — A.J. Plunkett (aplunkett@h3.group)

Resource:

CMS releases interpretive guidance on emergency preparedness

CMS unveiled interpretive guidance and survey procedures on its emergency preparedness rule. The emergency preparedness rule went into effect last November. The interpretive guidelines apply to all 17 provider and supplier types.

Read the full memo here. 

CMS publishes new emergency preparedness Interpretive Guidelines

On June 2, CMS published its final rule for emergency preparedness guidelines and survey procedures. These rules affect all 17 providers and suppliers and the rules will be enforced starting November 15, 2017.

While the survey process will remain the same, the new rule creates compliance tags for emergency preparedness requirements. These tags will be similar to how K-tags are used to cite noncompliance with the Life Safety Code® (LSC).

The emergency preparedness tags will be called “E Tags” and are accessible to both health and safety surveyors and LSC surveyors. State survey agencies will have the discretion to decide which surveyor group will conduct the emergency preparedness surveys.

Study: Single step reduces readmissions by 25%

A new study published in the Journal of the American Geriatrics Society has found that integrating informal, unpaid caregivers into the discharge process can cut readmission rates by a quarter. The study found that by using these caregivers when discharging elderly patients, they were able to reduce readmissions 25% over 90 days.  The study reviewed 4,361 patient cases and 10,715 scientific publications to come up with its results. The study found that:

•    66% of the caregivers were female
•    61% were a spouse or partner
•    35% were adult children

The study also found that informal caregivers significantly reduced time-to-readmission, rehospitalization lengths, and costs of post-discharge care.

“Due to medical advances, shorter hospital stays, and the expansion of home care technology, caregivers are taking on considerable care responsibilities for patients,” said lead author Juleen Rodakowski, OTD, MS, OTR/L, assistant professor in the Department of Occupational Therapy in the University of Pittsburgh’s School of Health and Rehabilitation Sciences, in a statement.

“This includes increasingly complex treatment, such as wound care, managing medications, and operating specialized medical equipment. With proper training and support, caregivers are more likely to be able to fulfill these responsibilities and keep their loved ones from having to return to the hospital.”

“While integrating informal caregivers into the patient discharge process may require additional efforts to identify and educate a patient’s family member, it is likely to pay dividends through improved patient outcomes and helping providers avoid economic penalties for patient readmissions,” said senior author A. Everette James, JD, MBA, director of the University of Pittsburgh’s Health Policy Institute, in a statement.

Caregiver statistics aggregated from the AARP, the Family Caregiver Alliance (FCA), the Institute of Medicine (IOM), and the National Alliance for Caregiving (NAC) reveal that:

•    More than 34 million unpaid caregivers provide care to someone age 18 and older who is ill or has a disability (AARP, 2008)
•    Unpaid caregivers provide an estimated 90% of the long-term care (IOM, 2008)
•    The majority (83%) are family caregivers—unpaid persons such as family members, friends, and neighbors of all ages who are providing care for a relative (FCA, 2005)
•    The typical caregiver is a 46-year-old woman with some college experience and provides more than 20 hours of care each week to her mother (NAC, 2004)

See the full article at HealthLeaders Media and read previous Accreditation Insiderarticles for more on readmissions:

Throwback Thursday: Hospital near-death ­experience: An organization’s fight for survival after CMS decertification

Editor’s Note: The following is a free Briefings on Accreditation and Quality article from yesteryear! If you like it, check out more of our work covering quality and accreditation! 

After reading this article, you will be able to:

  • Describe where an organization’s goals can be counterintuitive to quality
  • Discuss leadership’s role in decertification
  • Identify ways nursing staff are key to recertification
  • Discuss physician involvement in rescuing the facility after CMS decertification

 Closed Sign

The threat of loss of accreditation is one that keeps survey coordinators and hospital leaders awake at night, but for most hospitals, it’s more of a bogeyman than an actual threat-there are many stages an organization must go through and fail before their accrediting bodies slam the hammer down. However, a recent case of decertification and recertification by Medicare stands as a cautionary tale for hospitals across the country to never lose sight of the goals of quality and safety.

Compass Clinical Consulting, an independent consulting group, recently had the experience of helping one hospital recover from the rare event of decertification from CMS. (For the privacy of the organization, the hospital’s name has been omitted from this article.)

“How we got here is pretty straightforward,” says Kate Fenner, RN, PhD, managing director of Compass Clinical. “It was an organization with a very strong leader, and they were focused on entrepreneurship and building the base of the organization.”

The organization had been fairly aggressive in acquisition and reservice, and its board of trustees was on board with this concept. An unintentional downside to this approach, however, was the neglect of day-to-day clinical operations, says Fenner.

“They got very involved with growth-it became their mantra,” she says. “But making certain that their core business was well served did not hit high on the radar. Board meetings were dominated by financial discussions, acquisition discussions, real estate, and building, with little to no discussion about clinical quality or issues going on at the hospital.”

This lack of attention to clinical operations did not go unnoticed. Physicians became concerned-so much so that one physician submitted a complaint to CMS, bringing the state survey office in. The physician’s fears turned out to be legitimate, and the organization received an immediate jeopardy finding.

Too little too late

CMS wanted an action plan on how the deficiencies it found would be addressed. Amazingly, the board did not even know about the immediate jeopardy finding, says Fenner. Instead, the CEO-that same leader who had led the charge toward acquisition and growth-delegated addressing the CMS finding to the chief nursing officer (CNO), who was an interim CNO at the time.

“She did her best,” says Fenner. But despite the CNO’s efforts, CMS came back in and found the facility still out of compliance.

“The second immediate jeopardy had a tight timeline on it,” says Fenner. “Their CEO chose to say, ‘You can’t do that to us.’ Well, they can! CMS is like the IRS-they have a lot of power. And this was a legitimate clinical concern.”

Despite this, the state government gave the facility another opportunity to save itself-the surveyors even chose to stay in the area over a weekend, coming back on Sunday night, to give the organization one more chance to clean up and comply.

It failed.

“At this point they received notice of decertification,” says Fenner, whose organization was brought in to help. “I wish they’d called us a week or two earlier.”

 [Continued] [more]

CMS extends eCQM reporting deadline

In a new blog post, CMS announced that it was extending its electronic clinical quality measure (eCQM) submissions to March 13, 2017 at 11:59 p.m. PST. This gives facilities and extra 13 days to get their submissions in on time.

The data being submitted is from the 2016 reporting period, which will impact facilities’ 2018 fiscal year (FY) payments. The deadline applies to hospitals and critical access hospitals enrolled in either the Hospital Inpatient Quality Reporting (IQR) program or the Medicare Electronic Health Record (EHR) Incentive program. CMS Logo

“CMS also intends to initiate the rulemaking process regarding modifications to the eCQM requirements established in the FY 2017 Inpatient Prospective Payment System (IPPS) final rule in response to concerns raised by stakeholders,” Kate Goodrich, MD, CMS chief medical officer, wrote. “In order to help reduce reporting burdens while supporting the long term goals of these programs, we intend to include proposals regarding the 2017 eCQM reporting requirements for the Hospital IQR and EHR Incentive Programs for eligible hospitals and critical access hospitals in the FY 2018 IPPS proposed rule that we anticipate to be published in the late spring of 2017.”

CMS says it will address stakeholder concerns with the FY 2018 IPPS proposed rule. In particular, they will look at
•    Challenges associated with hospitals transitioning to new EHR systems or products
•    Upgrading to EHR technology certified to the 2015 Edition
•    Modifying workflows
•    Addressing data element mapping
•    Time allotted for hospitals to implement eCQM specifications updates in 2017

The agency is also proposing to adjust the number of eCQMs required to be reported for 2017 as well as to shorten the eCQM reporting period.
“We believe that these efforts reflect the commitment of CMS to create a health information technology infrastructure that elevates patient-centered care, improves health outcomes, and supports the healthcare providers who care for patients,” she wrote. “We continuously strive to work in partnership with hospitals and the provider community to improve quality of care and health outcomes of patients, reduce cost, and increase access to care.”

Want to receive articles like this one in your inbox? Subscribe to Accreditation Insider!