Prioritization of Survey Activities – CMS Guidance

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

On March 23, 2020, I blogged on the findings of the Kirkland nursing home and CMS’ new targeted survey activities.

CMS issued QSO-20-20-All which provides prioritization for surveys during the 3-week time frame beginning March 13, 2020:

  • Complaint/facility-reported incident surveys
  • Targeted Infection Control surveys
  • Self-assessments

“Therefore, during the prioritization period, the following surveys will not be authorized:

  • Standard surveys for long term care facilities (nursing homes), hospitals, home health agencies (HHAs), intermediate care facilities for individuals with intellectual disabilities (ICF/IIDs), and hospices. This includes the life safety code and Emergency Preparedness elements of those standard surveys;
  • Revisits that are not associated with IJ. As a result, the following enforcement actions will be suspended, until revisits are again authorized:
  • For nursing homes – Imposition of Denial of Payment for New Admissions (DPNA), including situations where facilities that are not in substantial compliance at 3 months, will be lifted to allow for new admissions during this time;
  • For HHAs – Imposition of suspension of payments for new admissions (SPNA) following the last day of the survey when termination is imposed will be lifted to allow for new admissions during this time;
  • For nursing homes and HHAs – Suspend per day civil money penalty (CMP) accumulation, and imposition of termination for facilities that are not in substantial compliance at 6 months.
  • For CLIA, we intend to prioritize immediate jeopardy situations over recertification surveys.”

There is a great deal of information in this notification that I don’t want you to miss, including the COVID-19 Focused Survey for Nursing Homes which begins on page 10 of this 28-page QSO.  I blogged and provided the Texas focused infection control materials back on March 18th – 2 days before the QSO-20-20-All was provided.  The TX document was based on the March 4, 2020 QSO.

There’s a lot happening with COVID-19 and I want to provide this most recent directive from CMS for you and your team to work from in terms of survey and compliance.