The Centers for Medicare and Medicaid Services (CMS) is empowered to survey an accredited provider to validate the accreditation process of the Accrediting Organization, e.g. The Joint Commission or DNV. While all hospitals are subject to periodic accreditation surveys, the CMS surveys can be extremely rigorous and stressful. In many cases, hospital senior management may be singularly focused on the survey for a period of months.
HFS has found that while hospitals are usually well equipped to deal with periodic surveys from organizations such as The Joint Commission, they may not be as prepared for a CMS survey. There are two types of validation surveys:
- Surveys conducted on a representative sample basis. These may be comprehensive surveys of all Medicare conditions or focused surveys on a specific condition or conditions.
- Surveys in response to a “substantial allegation” are generally the result of a complaint. These surveys focus on those Medicare conditions related to the allegations.
Sanctions Resulting From CMS Surveys
CMS surveys are performed within the context of Medicare “Conditions of Participation” and can result in sanctions, including monetary penalties or the threat of decertification from the Medicare program. Compounding this is the fact that these sanctions are in addition to any imposed by the California Department of Public Health in its citation process.
Is Your Facility A Candidate for a CMS Visit?
CMS surveys, like accreditation surveys, are unannounced, but there are some indicators that a facility may be a candidate for a CMS visit. Here are some questions to ask:
- Have we had frequent visits by CDPH following up on complaints?
- Did the last CDHP visit result in substantial allegations of noncompliance?
- Have we had a recent accreditation survey?
- Did our last accreditation survey result in a number of deficiencies?
Other things that can result in a CDPH or CMS focused or comprehensive survey:
- A death as a result of restraint or seclusion reported to CDPH and CMS.
- Alleged discrimination against anyone with HIV positive status.
- ESRD service complaints.
HFS Can Help
HFS has extensive experience in helping hospitals in quality management initiatives and preparing for accreditation surveys, including “mock” surveys. We have made assistance in the area of CMS surveys a priority, particularly in the area of survey preparedness. There have been about 20 CMS surveys in California in the past year. This is an area that deserves careful attention given the potential for a negative impact on a hospital’s reputation.
Becky Carroll, RN, MS heads up our program and can be reached at 510-867-1305 or firstname.lastname@example.org. Watch for further HFS alerts related to CMS surveys.