CMS Issues 2 Guidance Documents That You Need to Review!

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare®

Tuesday, March 5, 2019 was a busy day for CMS postings.  Two such postings should be reviewed by your team:




  • QSO-19-09-ALL is a 26-page document that speaks to the Appendix Q of the State Operations Manual (SOM). No effective nor implementation date is identified on pages 4 through 26 of the QSO-19-09-ALL posting.  Changes/revisions are identified in red ink throughout the Appendix.   Online basic training for Core Appendix Q is available on the Integrated Surveyor Training Website at the following link:

“Immediate jeopardy is a situation in which a recipient of care has suffered or is likely to suffer serious injury, harm, impairment or death as a result of a provider’s, supplier’s, or laboratory’s noncompliance with one or more health and safety requirements. Immediate jeopardy represents the most severe and egregious threat to the health and safety of recipients, as well as carries the most serious sanctions for providers, suppliers, and/or laboratories.

CMS provides guidance to surveyors for citing immediate jeopardy in Appendix Q of the SOM. The version of Appendix Q that is being replaced was drafted in 2004 and is being updated to clarify and increase consistency for identifying immediate jeopardy. These revisions apply to all provider and supplier types. The revisions also include subparts that are focus on specific concerns with nursing homes and clinical laboratories.”


Each of these areas need your attention so read the 5-page notice carefully.

You’ll also note that while the date of the posting of QSO-19-08-NH is March 5th, at the very end of the notice you’ll see an effective date of April 24, 2019.

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