Suspension of Audits During the Coronavirus?

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Effective immediately, survey activity is limited to the following (in Priority Order):

  • All immediate jeopardy complaints (cases that represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect;
  • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
  • Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities);
  • Any re-visits necessary to resolve current enforcement actions;
  • Initial certifications;
  • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
  • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

See CMS QSO-20-12-ALL.

Obviously, there are so many questions. Providers across the country are asking whether they need to comply with document requests. Are TPE audits continuing? Do they need to comply with ongoing ADRs?

Every bulletin that CMS publishes instigates more detailed and complex questions. With all these relaxed guidelines, won’t RACs, etc. have a field day when this is all over? Of course they will.

General Recommendations:

  • Be proactive.
  • Document everything.
  • Deadlines will be extended.
  • Exceptions will be made.
  • Keep all email correspondence.
  • Maintain copies of everything that you submit. (Do not rely on electronic computer software programs).
  • Keep track of CMS updates.

Email me questions, and I will try to respond.

Also, feel free to reach out to the government: QSOG_EmergencyPrep@cms.hhs.gov.

Effective date: 30 days from the memo, which equals April 3, 2020.

 

 

About kemanuel

Medicare and Medicaid Regulatory Compliance Litigator

Posted on March 30, 2020, in CMS, Coronavirus, Federal Government, Federal Law, Health Care Providers and Services, Knicole Emanuel, Lawsuit, Legal Analysis, Medicaid, Medicaid Attorney, Medicaid Audits, Medicaid Providers, Medicaid Services, Medicare, Medicare Administrative Contractor, Medicare and Medicaid Provider Audits, Medicare Attorney, Medicare Audits, Medicare RAC, Provider Appeals of Adverse Decisions for Medicare and Medicaid, RAC, RAC Audits, Regulatory Audits, Tentative Notices of Overpayment and tagged , , , , , , , , , , , , , , , . Bookmark the permalink. 1 Comment.

  1. Hello, Ms. Emanuel,

    Just a FYI from a HFEN in LA with current firsthand experience: Per CDC, all routine licensing surveys for SNF’s are on hold. All non-IJ complaints are on hold. We are completing as many complaints as possible telephonically.

    If necessary, we are expected to go onsite, but no PPE has been provided or is available for self-purchase.

    Thank you,

    Rochelle Sandell

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