We’ve established a new form for Network 16 facilities to report Involuntary Discharge or Transfer. Find the form and instructions for using it at https://www.nwrn.org/providers-and-professional-staff/patient-services/ivd.html.
The Conditions for Coverage (CfC) require all facilities to notify both the Network and your State Survey Agency, within specified time parameters, of all involuntary discharges and transfers. Better yet, if you’re considering an involuntary discharge or transfer, first contact the Network Patient Services Coordinator, Lisa Hall (email@example.com or 206-923-0714), to help you negotiate a better outcome.
For Network 18 facilities, see http://www.esrdnetwork18.org/providers/patient-services/.
CMS requires Networks to track the status of facility operations and patient access to treatment during emergency events like the recent major earthquake in Alaska. 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.
Find requirements and recommendations on earthquake preparedness for patients and providers at:
CMS is seeking public comment on a Proposed Rule for Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction. Comments will be due sixty days after the Proposed Rule is published in the Federal Register, probably around November 20, 2018. A pre-publication copy of the Proposed Rule can be found at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-19599.pdf. A quick and not exhaustive scan of the Proposal finds matters relevant to Transplant Centers at p.13, pp.69ff, 129ff, 183ff, 243ff, and 274ff, and matters relevant to Dialysis Facilities at pp.85-86, p.101, pp.104ff, 110-111, 142ff, 203ff, 217ff, and 281ff.
CMS has published a comprehensive update of chapter 2 (ESRD) of the State Operations Manual (SOM), which describes the oversight activities of State Survey Agencies for certified Medicare providers and suppliers. Chapter 2 of the SOM includes guidance and instructions on procedures for ESRD facilities, including nursing homes. The update incorporates current Conditions for Coverage, and CMS policies for ESRD issued previously through memoranda. Find the document at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/QSO18-22-ESRD.pdf.
The November 2017 issue of Network 16 News focuses on the new CMS Emergency Preparedness Rule for dialysis facilities. The Rule requires two exercises per year, one of which must be full-scale. The other can be what they’re calling a “table-top” exercise, or a disaster-response simulation. The bulk of the News issue describes a sample table-top exercise. The Question Corner deals with what State Surveyors will look for when assessing facility compliance with the Rule.
Another article advises that you need to know your facility’s “CCN” or CMS Certification Number. This 6-digit number uniquely identifies your facility, and avoids the confusion of multiple or ambiguous facility names. For instance, in CROWNWeb there are facilities that have entered their facility name as “Fresenius Medical Care” and “Pacific Northwest Renal.” If a facility reported a name like this during a disaster, rather than their CCN, the Network would have to call fifty facilities to find the one with the emergency.
November’s News also flags the March 8-9, 2018 NWRD Annual Conference in Spokane and the April 11-14, 2018 NKF Spring Clinical Meetings in Texas in the “Hot Dates” section. See our Facility Calendar at https://nwrnbulletins.wordpress.com/staff-education-calendar/ for more information on these and other dates.
Current and historical Network 16 News issues are online at https://nwrn.org/providers-and-professional-staff/nw16n.html .
The new CMS Emergency Preparedness Rule for dialysis facilities will be enforced starting November 15, 2017. The Kidney Community Emergency Response Coalition (KCER) has prepared resources for facilities, including Interpretive Guidelines and Survey Procedures, a Survey Tool, and a Knowledge Center. Find them at http://www.kcercoalition.com/en/resources/professional-resources/ .
The Rule requires dialysis facilities to conduct two emergency preparedness exercises per year. One must be full-scale, but the other may be a “table-top exercise,” a group discussion led by a facilitator using a narrated, clinically-relevant emergency scenario that challenges an emergency plan. KCER is also preparing a variety of table-top exercise templates that facilities may copy; see http://www.kcercoalition.com/en/resources/professional-resources/table-top-exercises/ .