RSSAll Entries Tagged With: "CMS"

Thoughts about all that documentation the CoPs require? CMS wants to know

Have thoughts about the paperwork you have to generate because of Medicare’s Conditions of Participation (CoP)? Or rather, do you have thoughts you’d like to share with the public, as well as the Department of Health and Human Services (HHS)?

Now’s your chance. CMS has posted a call for comments on the paperwork required under the regulations that govern almost every aspect of operations at hospitals nationwide that also want the ability to bill Medicare for their services.

The call for public comment is periodic request, mandated in turn by the Paperwork Reduction Act of 1995. (So yes, it’s a regulatorily required chance to comment on extraneous regulations.)

And it’s one of many CMS puts out through the year. This particular request, according to the formal notice placed in the Federal Register Nov. 13, concerns the regular collection of information “needed to implement the Medicare and Medicaid Conditions of Participation (CoP) for 4,890 accredited and non-accredited hospitals and an additional 101 critical access hospitals (CAHs) that have distinct part psychiatric or rehabilitation units (DPUs). CAHs that have DPUs must comply with all of the hospital CoPs on these units. Thus, this package reflects the burden for a total of 4,991 hospitals (that is, 4,890 accredited/non-accredited hospitals and 101 CAHs which include 81 CAHs that have psychiatric DPUs and 20 CAHs that have rehabilitation DPUs).”

Translated, that’s most of the hospitals in the nation, minus the 1,183 CAHs without distinct part psychiatric or rehabilitation units. They operate under a separate set of CoP, according to the notice.

“The CoPs and accompanying regulatory requirements are used by our surveyors as a basis for determining whether a hospital qualifies for a provider agreement under Medicare and Medicaid. CMS and the health care industry believe that the availability to the facility of the type of records and general content of records is standard medical practice and is necessary to ensure the well-being and safety of patients and professional treatment accountability,” according to the notice.

CMS estimates that the paperwork required to meet the CoPs of the combined 4,991 respondents generates 1,342,424 responses a year, requiring a total of 18,840,617 hours a year.

That’s about 3,775 hours per hospital. Or 72 hours a week. Or basically two full-time positions a year.

(You might not want to ask one of those people to generate the report to send to Medicare, if you do decide to submit a comment.

Or you might.)

Comments must be received by Jan. 12, 2018.

After the notice is published on Nov. 13, to comment electronically — no physical paperwork needs to be generated! — go to www.regulations.gov, search for “2017-24524,” hit the button that says “COMMENT NOW” and follow the instructions.

Note the warning that the comments will be made public.

Or you can send comments by regular mail: CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention: Document Identifier/OMB Control Number 2017-24524, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850.

To read the request of information first, go to https://www.gpo.gov/fdsys/pkg/FR-2017-11-07/pdf/2017-24134.pdf 

— Written by A.J. Plunkett (aplunkett@h3.group)

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 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]

New CMS requirements for fire door inspection

The American Society for Healthcare Engineering (ASHE) recently published answers involving CMS’ new fire safety regulations. The new Conditions of Participation require fire doors be routinely inspected by “qualified persons.”

ASHE clarified to members that there isn’t any class or certification to qualify for door inspection. Anyone who’s familiar with the code requirements for fire doors will meet the “qualified” standard.

For more details, see the ASHE brief on the topic.

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!

 

The New CMS Emergency Management Rule: Tips for Successful Implementation

Date: Tuesday, January, 24, 2017 1:00–2:30 p.m. EST

Summary: After much anticipation, CMS has approved its own emergency preparedness rules separate from The Joint Commission and other accreditation agencies. Hospitals and healthcare organizations now have until November 15, 2017 to enact the changes and maintain compliance.HCPro Webcast Icon

Join expert speakers Marge McFarlane, PhD, MT(ASCP), CHSP, CHFM, CJCP, HEM, MEP, CHEP, and Thomas Huser, MS, CHSP, CHEP, as they guide you through the changes. They will help you identify resources for implementation, provide helpful tips, outline the special focus on fire drills for critical access hospitals, and list the optional and required CMS emergency management standard categories.

This webcast will teach you:

  • The list of required and optional categories of the CMS emergency management regulations
  • The tips, resources, and potential challenges to implementing an emergency prep plan
  • How to conduct fire drills for critical access hospitals

Registration: To order the webcast on demand, call HCPro customer service at 800-650-6787 or visit hcmarketplace.com

AHA asks Trump to change CMS regulations

On December 2, the American Hospital Association (AHA) sent a letter to president-elect Donald Trump asking him to reform CMS regulatory requirements. This is the second letter the group sent the president-elect in the space of three days.

The AHA has 43,000 individual members and nearly 5,000 member hospitals in its ranks. AHA CEO and President Rick Pollack wrote that the balance between flexibility in patient care and regulatory burden was at a tipping point. He continues to say that reducing administrative complexity would save billions annually and allow providers to spend more time on patients, not paperwork.The White House

“[CMS] and other agencies of the Department of Health and Human Services (HHS) released 43 hospital-related proposed and final rules in the first 10 months of the year alone, comprising almost 21,000 pages of text,” he wrote. “In addition to the sheer volume, the scope of changes required by the new regulations is beginning to outstrip the field’s ability to absorb them. Moreover, this does not include the increasing use of sub-regulatory guidance (FAQs, blogs, etc.) to implement new administrative policies.”

CMS LogoThe letter includes a list of 33 changes the AHA wants to be made, including

•    Suspend hospital star ratings
•    Suspend electronic clinical quality measure (eCQM) reporting requirements
•    Delete faulty hospital quality measures
•    Have readmission measures reflect socioeconomic factors
•    Cancel stage 3 of “meaningful use” program.
•    Stop federal agencies (HHS, CMS) from forcing private sector accreditors (Joint Commission, DNV, HFAP) to conform with government accreditation standards
•    Refocus the Office of the National Coordinator (ONC) on certifying electronic health records

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

Study: Link between CMS hospital star ratings and socioeconomic factors

It’s been almost five months after CMS publicly released its hospital star ratings system amidst widespread controversy and opposition. Now, a new study by WalletHub has provided evidence that hospitals’ ratings are highly linked to their location and socioeconomic factors.

CMS LogoEver since CMS announced the star system, many had argued that it was biased against facilities that treat impoverished, sicker patients. To study this, WalletHub looks at the ratings of 657 hospitals in 150 cities across the U.S. comparing ratings to each city’s “stress level,” a composite of stressor caused by work, money, family, and health and safety. Star Rating

Hospitals in Detroit and Newark, N.J. (the first and ninth most stressed cities) earned an average of 1.5 and one stars respectively. However, hospitals in the California cities of Fremont and Irvine (the least and second-least stressed cities) earned an average of three and five stars, respectively. Meanwhile, CMS reports that safety net hospitals earn slightly lower ratings on average compared to non-safety net hospitals (2.88 to 3.09 stars).

“When we look at hospital quality ratings and rankings, what we are seeing has less to do with what the hospitals themselves are doing and more to do with the communities they are located in and the patients they serve,” said David Nerenz, co-author of the study and the director of the Center for Health Policy and Health Services Research at the Henry Ford Health System in Detroit, to Modern Healthcare. [more]