7/16 KCER After-Action Report Webinar

KCER will present a July 16, 2020 webinar for dialysis facilities on The Basics of Preparing an After-Action Report for an Incident or Disaster.  The webinar presents KCER’s template for After-Action Reports (“AAR”) and includes instructions for meeting the CMS Emergency Preparedness Rule for dialysis facilities, and specific guidance for AARs on your response to COVID-19.  Find more information in the flyer below.  Click HERE to register.  Contact KCER at kcerinfo@hsag.com for questions or assistance.

An AAR describes an event or process that for any reason you needed or wanted to respond to or improve, how you responded, your evaluation of the effectiveness of your response, and any improvements you recommend for “next time,” or to complete or enhance your response to the current issue.

HDC on Safe Social Work and COVID-19

Home Dialysis Central has published a blog post on Dialysis Social Work During a Pandemic: Caring for Patients Safely, thoroughly reviewing what are permitted and required by:

  • CMS Conditions for Coverage,
  • Social Work licenses and training,
  • Medicare reimbursement rules and waivers,
  • Patient and staff safety,
  • Home dialysis,
  • Effective communication,
  • PPE,
  • Telehealth,
  • Comparative advantage,

all in the context of the COVID-19 pandemic.  Find the post at https://homedialysis.org/news-and-research/blog/361-dialysis-social-work-during-a-pandemic-caring-for-patients-safely.

5/26+ CMS Shareholder Engagement Calls

CMS is hosting weekly Stakeholder Engagement sessions to share information related to the agency’s response to COVID-19.  These sessions are open to the healthcare community and provide updates, share best practices, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.  Conference lines are limited so we encourage you to join via audio webcast on your computer or smartphone web browser.  You are welcome to share this invitation with your colleagues and professional networks, but these calls are not intended for the press.  Call recordings and transcripts are posted on the CMS podcast page at: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.

Targeted Updates for Dialysis Organizations on the agency’s latest COVID-19 guidance, also featuring leaders in the field sharing best practices, with an opportunity to ask questions if time allows.  Wednesday May 27, 2020, 2:30-3:00 pm PDT, toll-free 833-614-0820, passcode 6152699, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2123#/main/simplify.

COVID-19 Office Hours Calls are an opportunity for providers to ask questions of CMS officials about temporary actions that allow increased capacity, expanded workforce, patient priority, and telehealth.  Tuesday May 26, 2020, 2-3pm PDT, toll-free 833-614-0820, passcode 8977438, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2012#/main/simplify.

Lessons from the Front Lines with representatives from CMS, FDA, and the Coronavirus Task Force, along with front-line clinicians.  Friday May 29, 2020, 9:30-11:00 am PDT,  toll-free 877-251-0301, passcode 6350189, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2075#/main/simplify.

6/1 Comments Due on CMS Flexibility Rules Change

CMS has published an Interim Final Rule with Comment Period on the Flexibility changes in Medicare rules made on March 31, 2020.  The Comment Period will expire June 1, 2020.  For details and comment see Medicare and Medicaid Programs: Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency at https://www.regulations.gov/document?D=CMS-2020-0032-0013.

CMS Summary of COVID-19 Waivers as of 4/9

On April 9, 2020 CMS published a document on COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, summarizing relief during the current emergency from normal requirements, with the intention to allow healthcare facilities to focus more attention on treating COVID-19 patients.  Waivers for dialysis facilities are summarized on pp.17-19, and include adjustments to regulations for water quality testing, fire inspections, patient assessments, plan of care, rounds, home visits, special purpose facilities, PCT certification, transferability of professional credentials, dialysis in nursing homes, and many other details.  Find the document at https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDEsInVyaSI6ImJwMjpjbGljayIsImJ1bGxldGluX2lkIjoiMjAyMDA0MTAuMjAwMTg1NTEiLCJ1cmwiOiJodHRwczovL3d3dy5jbXMuZ292L2ZpbGVzL2RvY3VtZW50L3N1bW1hcnktY292aWQtMTktZW1lcmdlbmN5LWRlY2xhcmF0aW9uLXdhaXZlcnMucGRmIn0.NmtjnP-P1fvfNYld0nlhqMouY3FZb10Xx7Aull2AIwA/br/77281657281-l.

Notify Network of Service Disruptions

CMS requires ESRD Networks to track the status of facility operations and patient access to treatment at all facilities. If the operations of your facility, or ability for patients to have access to dialysis, are interrupted for any reason, let your Network know as soon as possible.

In Washington, Oregon, Idaho, Montana, and Alaska (Network 16), fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393 (the completed form gets routed back to Network 16).  If you need assistance, you may also call or email Lisa Hall at 206-923-0714 or LHall@Comagine.org, or Brianna Smith at 509-306-8313 or BSmith2@Comagine.org.

In Southern California (Network 18), fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/embed.php?id=16298.  If you need assistance, you may also call Eileen Rhodes or Anabel Galindo-Guerrero at 888-268-1539, or email them at ERhodes@Comagine.org or AGalindo-Guerrero@Comagine.org.

Never put patient name, initials, address, birthdate, SSN, other identifying information, or any other PHI or PII, in an email or online form. If PHI or PII is important in this context, call instead.

Notify Network of Service Disruptions

CMS requires ESRD Networks to track the status of facility operations and patient access to treatment during emergency events at all facilities, including disruption due to the COVID-19 coronavirus.  If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

For Washington, Oregon, Idaho, Montana, and Alaska (Network 16), call Lisa Hall at 206-923-0714 or email LHall@Comagine.org, or Brianna Smith at BSmith2@Comagine.org.  We also ask that you fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393.  Network 18 will forward the completed form back to Network 16.

In Southern California (Network 18), call Eileen Rhodes or Anabel Galindo-Guerrero at 888-268-1539, or email ERhodes@Comagine.org or AGalindo-Guerrero@Comagine.org, and fill out the form at http://www.esrdnetwork18.org/machform/embed.php?id=16298.

Never put PHI or PII in an email or online form.  Examples include patient name or initials, birthdate, SSN, and other identifying information.

>2/21 Revised CMS State Operations Manual

CMS has published revisions to the State Operations Manual, including Appendix H – ESRD Facilities, Appendix X – Organ Transplant Program, and Appendix Z – Emergency Preparedness.  Find the revised Manual, which is effective as of February 21, 2020, at https://www.cms.gov/files/document/r200soma.pdf.  The 700-page manual lacks page numbers or other indications of which appendix you’re reading, but online PDF readers provide page counts in the upper left-hand corner, or at the top of the screen.  Changes include:

  • pp. 175ff: Appendix H – ESRD Facilities.  Guidance to Surveyors in Appendix H is extensively revised throughout, including updates to the regulatory text based on requirements set forth in the 2008 Conditions for Coverage and revisions based on recent Federal Fire Safety Requirements.
  • pp. 614ff: Appendix X – Organ Transplant Programs.  Revisions include Survey Protocol Tasks, and occasional other revisions scattered throughout.
  • pp. 657ff: Appendix Z – Emergency Preparedness.   Major revisions are included throughout.

Notify Network of Service Disruptions

It’s still relatively balmy in Southern California, but winter is getting serious in Network 16.  CMS requires ESRD Networks to track the status of facility operations and patient access to treatment during emergency events at all facilities.  If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

You are reminded never to put PHI or PII in an email or online form.  Examples include patient name or initials, birthdate, SSN, and other identifying information.

Transplant CoP Changes

Modifications to the Conditions of Participation for kidney transplant programs (formerly transplant centers) have been published in the Federal Register for September 30, 2019.  They will take effect on November 29, 2019.  The primary change is that an approved transplant program will no longer be required to submit outcome data for periodic re-approval.  The modifications are summarized by the American Society of Transplant Surgeons at https://asts.org/news-and-publications/asts-news/article/2019/09/27/cms-removes-outcomes-requirement-for-transplant-center-re-approval, and detailed in the Federal Register at https://www.govinfo.gov/content/pkg/FR-2019-09-30/pdf/2019-20736.pdf, pp.51748-50.