THE
SURVEYOR
I FALL 2013
REDUCING YOUR RISK
[
HOME HEALTH ]
With the implementation of the first phase of CMS sanctions for Home Health providers
on July 1, 2013, agencies across the country are rightfully concerned about what resources
are available to help them avoid steep penalties and ensure compliance with Medicare
Conditions of Participation (CoPs). With fines totaling thousands of dollars per day on the
horizon, a strong compliance program achieved through earning and maintaining ACHC
accreditation is a key strategy for avoiding fines that could potentially put your agency
out of business. Since ACHC standards are written for providers, by providers, and are
also based upon the Medicare CoPs; agencies that achieve and maintain accreditation
have taken an important step in reducing their risk.
In addition to the already widely-recognized benefits of accreditation, the
following are examples of how ACHC will help you avoid these sanctions:
All condition-level and standard-level violations cited during any on-site survey
conducted by ACHC are not subject to the CMS sanctions.
For providers who have deemed status, CMS only conducts on-site surveys for
complaint or validation purposes, significantly limiting the risk of an on-site visit
during which sanctions could be imposed.
New Home Health agencies are frequently less familiar
with CMS requirements. ACHC providers have access to
a variety of resources, as well as a personal Accreditation
Advisor and surveyors with industry-specific experience
aimed at helping you before, during and after the
accreditation process.
Proper education of staff is also a key component to establishing and
maintaining a strong compliance program, especially as it relates to
the implementation of policy in direct patient care. During your on-site
accreditation survey, your surveyor will be evaluating staff providing
patient care to ensure it is reflective of both professional standards
of practice and agency policy. ACHC also provides audit tools to ensure
compliance with essential standards related to pers onnel records, client
charts and other required documentation and standards.
EXAMPLES OF UPCOMING SANCTIONS
CIVIL MONEY PENALTIESCMS may impose a civil money
penalty against an HHA for
either the number of days the
HHA is not in compliance or for
each instance the HHA is not
in compliance. Penalties can
range up to $10,000 per day.
EFFECTIVE DATE: JULY 1, 2014
SUSPENSION OF PAYMENT
FOR ALL NEW ADMISSIONSCMS may suspend payment for
all new Medicare admissions
regardless of whether the
Condition Level deficiencies
pose immediate jeopardy.
EFFECTIVE DATE: JULY 1, 2014
A complete list of sanctions can be found at cms.gov.
ABOUT THE SANCTIONS
CMS-stated sanctions are
applicable in the event of a
condition-level deficiency, unless
the standard-level deficiency is
considered to impose significant
harm to an individual or if an
agency has a standard-level
deficiency previously found to
be a conditional-level deficiency.
CMS will delay the application
of civil money penalties,
payment suspension and the
Informal Dispute Resolution
(IDR) process until July 1, 2014.
For more information about the
CMS sanctions, read the Federal
Register, Vol. 77, No. 217 published
November 8, 2012.