CMS Again Limits Onsite Surveys, Citing Risks from COVID-19 Surges

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The Centers for Medicare and Medicaid Services (CMS) notified state survey agency directors of renewed hospital survey limitations and notification expectations for states and hospitals during the ongoing COVID-19 crisis in the United States. Citing the risks associated with onsite survey activity during the recent COVID-19 surges in several states, CMS put these limitations in place for an initial period of 30 days and provided a mechanism for renewals to extend that time period.

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CMS issued a Quality, Safety & Oversight Group and Survey & Operations Group memoranda addressed to state survey agency directors on January 20, 2021, effective immediately, outlining hospital survey limitations and notification expectations for states and hospitals when their hospitals implement crisis standards of care.

The memo, entitled Hospital Survey Priorities (QSO-21-13-Hospitals), announced the following hospital survey limitations in effect for 30 days from the date of issuance, with the potential for 30-day renewals following additional notice:

  • Hospital Complaint Surveys are restricted to immediate jeopardy complaint allegations
  • Hospital Recertification Surveys are suspended, except for a subset of hospital reaccreditation surveys, per additional guidance that will be forthcoming
    • Hospitals due to receive a recertification or reaccreditation survey will have their certification automatically extended for at least 30 days
    • Additional guidance on accrediting organization reaccreditation surveys will be forthcoming
  • Hospital Enforcement Actions for deficiencies that do not represent immediate jeopardy will have the termination date extended for at least 30 days
    • Hospitals do not need to submit a plan of correction or have a revisit survey by the state survey agency
    • Hospitals that have an uncorrected immediate jeopardy must demonstrate removal of findings through an onsite survey
    • Following this 30-day period, hospitals will have up to 60 days to demonstrate compliance with any outstanding deficiencies, as outlined in forthcoming guidance

CMS also requested that hospitals contemplating or implementing crisis standards of care notify their appropriate state health agency, and that states with hospitals in or approaching crisis standards of care contact their CMS Survey Operations Group location for information about additional flexibilities and assistance. This is a new ask by CMS and suggests that the agency anticipates being more involved in circumstances where hospitals are contemplating drastic action due to the pressures of the pandemic.

The memo also links to previously issued CMS waivers and flexibilities intended to expand capacity, enhance staffing and assist hospitals in meeting the needs of their community during the pandemic, reminding providers of the potential opportunities to avail themselves of these tools to address identified operational concerns.

CMS indicated that it will issue further guidance as the situation evolves and the 30-day timeframe expires.

Key Takeaways

Hospitals in the midst of a survey cycle or otherwise anticipating ordinary course survey activity may find those efforts delayed in accordance with the guidance provided in the memo. Chance for delays notwithstanding, hospitals should consider the request to stay in close communication with CMS regarding the implementation of crisis standards of care and reevaluate the possibility of utilizing waivers and flexibilities in meeting the unique operational challenges posed by the pandemic.