A representative from the Centers for Medicare & Medicaid Services Office of Clinical Quality and Standards presented an overview of important news and updates from CMS’ Survey and Certification Group. The Survey and Certification Group serves as the focal point for all quality, clinical, medical science issues, survey and certification, and related policies for CMS’ programs. Topics covered during the session included plans for implementation of home health survey sanctions, the status of revised home health conditions of participation, and an overview of the top ten survey citations and most frequent OASIS errors.
Survey and Enforcement Requirements for Home Health Agencies
The presenter advised the audience that CMS surveys will place an emphasis on continued – rather than cyclical – compliance. Surveyors will determine whether policies are established to correct deficient practices and if the correction is lasting. Additionally, surveyors must determine if home health agencies’ deficiencies are addressed promptly, and whether or not the HHA in question takes the initiative and responsibility for monitoring performance to sustain compliance.
The top ten survey deficiencies for 2011 reported were:
- G158 – Written Plan of Care established & periodically reviewed
- G337 – Assessment includes review of all medications
- G159 – Plan of Care covers diagnosis, required services, visits, etc.
- G236 – Record with past/current findings maintained for all patients
- G121 – Compliance with accepted professional standards/principles
- G170 – Skilled Nursing Services furnished in accordance with Plan of Care
- G143 – Coordination of Patient Services
- G229 – Supervisory visits if skilled care no less than once every 2 weeks
- G176 – RN prepares notes, coordinates, informs MD, other staff of changes
- G165 – Drugs and treatment administered only as ordered by physician
Home Health Survey Sanctions
The speaker also reported on the status of implementation of alternative sanctions. CMS plan to impose sanctions beginning July 1, 2013, with the exception of civil money penalties and payment suspension. Monetary penalties will be imposed beginning July 1, 2014.
Sanctions, which can remain in place for up to six months, include:
- 488.835 – Temporary management
- 488.840 – Suspension of payment for all new admissions
- 488.845 – Civil money penalties
- 488.850 – Directed plan of correction
- 488.855 – Directed in-service training
- 499.860 – Continuation of payments to an HHA with deficiencies
- 488.865 – Termination of provider agreement as the final action should a provider fail to come into compliance.
Home Health Conditions of Participation
The speaker also reported that home health conditions of participation are once again in clearance and slated forfast-track approval. The audience was reminded, however, that multiple versions of the home health conditions of participation (CoP) have been through CMS clearance since a proposed rule was published in 1997 with no resultant publication of a notice of proposed rulemaking.
OASIS Transmission Errors
The presentation closed with a listing of the top ten OASIS transmission errors. Many of the reported errors were a repeat of those that occurred in the previous year, including the top three:
- Inconsistent M0090/Submission Date
- Duplicate assessment
- Inconsistent record sequence
It was reported that over 2 million OASIS records did not meet the required 30-day submission timeline.