Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
Late in the afternoon of September 6, 2019, CMS posted an update to Appendix Q – Core Guidelines for Determining Immediate Jeopardy, effective immediately.
The 6-page update is part of CMS Transmittal 192. CMS has revised guidance to reinsert language referring criminal acts to law enforcement:
Guidance for Reporting to Local Law Enforcement: When the identified noncompliance is determined to have been caused by a suspected criminal act and the entity refuses to report, or the surveyor cannot verify that a report was made to local law enforcement, the surveyor must consult with his/her supervisor immediately. The State Agency must then report the suspected criminal act to law enforcement immediately.
The advance copy of Appendix Q was posted July 31, 2019. Today’s posting is the official update to the SOM.