Sequestration Impact on Survey and Certification Activities
April 19, 2013 11:56 AM
In response to the across-the-board federal budget reductions under the sequester as mandated by the Balanced Budget and Emergency Deficit Control Act the Centers for Medicare & Medicaid Services (CMS) Survey & Certification (S&C) Group announced plans for certain budgetary adjustments. CMS notified State Agency (SA) Directors of planned adjustments that affect State operations in an April 5, 2013 letter.
In the letter, CMS advised SA Directors that the overall FY2013 S&C Medicare budget was reduced by 5 percent, with the expectation that State allocations will be reduced by 2.5 - 3 percent. CMS announced that the remaining reductions will be accommodated by reducing expenses, suspending additions to the workload, reducing time spent on lower risk areas and reducing CMS Central Office services. In order to accommodate this reduction, certain survey activities are to be placed on hold.
CMS prioritizes survey activities according to four tiers. Tier I is comprised primarily of statutorily-required surveys of nursing homes and home health agencies, as well as potential immediate jeopardy complaint investigations and certain validation surveys. Tier II is comprised primarily of other complaint investigations and targeted surveys of a sample of providers whose past performance data indicate a high likelihood of non-compliance with CMS quality of care or safety requirements. Tier III is comprised primarily of survey frequency intervals for all providers whose frequency is not specified in law, together with initial surveys of providers newly seeking Medicare participation and who do not have the option of seeking deemed status through accreditation by a CMS-approved accrediting organization. Tier IV consists primarily of additional survey frequencies for providers, as well as initial surveys of providers newly seeking Medicare participation who do have the option of seeking deemed status through accreditation by a CMS-approved accrediting organization.
SAs were advised in the April 5 letter to continue to adhere to CMS survey priorities necessary to ensure quality, including onsite complaint investigations and surveys of existing providers. The following are changes to SA survey activities applicable to home health and hospice providers:
Purchasers that Elect to Decline Medicare Assignment
CMS instructed SAs to inform providers that seek to purchase other providers, but decline assignment of Medicare certification, that there may be longer wait times for onsite surveys and certification work necessary before Medicare participation may be resumed. These waits will apply regardless of who might conduct the survey (State, accrediting organization, or CMS). In addition, SAs must obtain CMS Regional Office (RO) agreement before conducting surveys where a provider is not accepting assignment.
With respect to onsite revisit surveys that are conducted to confirm that a provider has remedied all health and safety noncompliance and restored its program to compliance with CMS requirements, SAs must obtain CMS RO approval before conducting any onsite revisit surveys after an initial revisit found that the provider had still not restored its program to substantial compliance. In addition, SAs must inform affected providers of a longer than normal wait time for revisits.
Home Health Targeted Surveys
Specific to home health agencies, CMS instructed SAs to discontinue all further Tier II targeted surveys of home health agencies that have been identified as having the lowest performance, unless directed to do so by CMS. However, SAs must continue to ensure that no more than three years elapse without an onsite recertification survey of all home health agencies.
These new reductions to S&C activities are in addition to those outlined in a CMS letter issued to SAs from December 9, 2011 directing them to:
Continue to follow the longstanding directive to ensure that all other surveys take precedence over surveys of providers that newly seek Medicare participation - i.e. Tier IV surveys.
Expand the Tier III maximum time interval between surveys of any one Hospice facility to once every 7 years from once every 6.5 years.