CMS Survey & Certification Memos

CMS released several S&C Memos to State Survey Agencies in the middle and end of September.  Below are a brief descriptions of each. The full memos are accessible in the Members Only section of the IHCA website.  Please note significant additional guidance to surveyors in the last two memos regarding Advance Directives and End of Life care. Please contact Zach Cattell at zcattell@ihca.org or 317-616-9001 with any questions or to obtain exhibits.

12-43: Impact of Nursing Shortage on Hospice Care (9/14/12)
The period of time has been extended for hospices to qualify for an “extraordinary circumstance” exemption when they believe that the nursing shortage has affected their ability to directly hire sufficient numbers of nurses. The effective date of this policy has been extended from September 30, 2012 to September 30, 2014.

12-44: “Hand in Hand: A Training Series for Nursing Homes,” on Person-Centered Care of Persons with Dementia and Prevention of Abuse (9/14/12, revised 9/27/12)
Section 6121 of the Affordable Care Act requires the Centers for Medicare & Medicaid Services (CMS) to ensure that nurse aides receive regular training on how to care for residents with dementia and on preventing abuse.  CMS created the Hand in Hand training materials to address the requirement for annual nurse aide training on these important topics. The training program consists of an orientation guide and six one-hour video-based modules, each of which has a DVD and an accompanying instructor guide.  Though Hand in Hand is targeted to nurse aides, it may be valuable to all nursing home caregivers, administrative staff and surveyors. The revised memo indicates that the materials will be sent free to all nursing homes, Regional Offices (RO) and State Survey Agencies no later than December 2012. 

12-45: Advance Copy of Interim Guidance - Revisions to State Operations Manual (SOM), Appendix P-Traditional Survey Protocol for Long-Term Care (LTC) Facilities and Chapter 9/Exhibits including Survey Forms 672, 802, 802S and 802P. (9/27/12)
Survey Protocols for LTC Facilities have been revised for the Traditional Survey process Tasks 1-5C in Appendix P to reflect changes for the: Minimum Data Set (MDS) 3.0; New Quality Measures (QM) Reports; Revised CMS forms 672 and 802, 802S and 802P; and Sampling and reviewing residents receiving psychopharmacological medications, specifically antipsychotic medications. Various Exhibits in Chapter 9,  including survey forms, have been revised to accommodate changes for MDS 3.0 and the new QM Reports. New QM Reports are available for use in the Traditional Survey Process.

12-46: F tag 322—Feeding Tubes (9/27/12)
Revisions have been made to Guidance to Surveyors at F tag 322 in Appendix PP of SOM concerning Feeding Tubes.  F tag 321 is deleted and the regulatory language and guidance moved to F tag 322.   Click here to access ower Point training material with speaker notes for Centers for Medicare & Medicaid Services (CMS) Regional Offices (ROs) and State Survey Agencies (SAs) to be used to train surveyors on this revision to F tag 322 in the SOM. The revisions should be implemented no later than November 30, 2012.

12-47: F tag 155-- Advance Directives (9/27/12)
Revisions have been made to Surveyor Guidance at F tag 155 in Appendix PP of the SOM, to include resident’s rights to: Establish Advance Directives and Accept or decline treatments. An advance copy of the surveyor guidance revision is included in the memorandum.  Click here to access Power Point Training material with speaker notes for Centers for Medicare & Medicaid Services (CMS) Regional Offices (ROs) and State Survey Agencies (SAs) to be used to train surveyors on this revision to F tag 155 in the SOM. The revisions should be implemented no later than November 30, 2012.

12-48: F tag 309—Quality of Care – End of Life (9/27/12)
Revisions have been made to Guidance to Surveyors at F tag 309 in Appendix PP of SOM regarding End of Life Care. Click here for Power Point training material with speaker notes for Centers for Medicare & Medicaid Services (CMS) Regional Offices (ROs) and State Survey Agencies (SAs) to be used to train surveyors on this revision.  The revisions should be implemented no later than November 30, 2012.