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.

NW16 WA Suspension of CoN until 4/29

Governor Inslee’s Proclamation 20-36 has waived Washington State Certificate of Need requirements for new health care infrastructure until April 29, 2020.  Dialysis facilities can without prior approval add stations where needed to help with isolation clinics, or to build out capacity at clinics that are not isolation clinics in order to move patients around to have the capacity needed at the isolation clinics.  For details see https://www.governor.wa.gov/sites/default/files/proclamations/20-36%20-%20COVID-19%20-%20DOH%20Health%20Care%20Facilities-Hand%20Sanitizer%20%28tmp%29.pdf.

4/1 NW16 WA Revised CoN Application Form

Washington State DOH has revised the application form that providers and potential providers must use to request a Certificate of Need to build a new or expand an existing dialysis facility in Washington State.  Find a copy of the revised application at https://www.doh.wa.gov/Portals/1/Documents/2300/2019/ESRDApp2019.pdf.  Letters of Intent for the 2019 “Special Circumstances, Cycle One” review of CoN applications must be filed by April 1, 2019.  Call 360-236-2955 or email DOH at FSLCON@doh.wa.gov if you have questions.  For more information on Washington CoN, see https://www.doh.wa.gov/LicensesPermitsandCertificates/FacilitiesNewReneworUpdate/CertificateofNeed.

NW16 WA 2/15 CoN Data Submission

Dialysis providers that wish to be considered during 2019 in Concurrent Review situations for Washington State dialysis facility applications must file specific information with the WA Department of Health Certificate of Need Program before February 15, 2019.  WA DOH has already downloaded information on Home Training, Shift Beginning After 5pm, SMR, and SHR from your DFC or DFR, and TPS from your QIP PSR.*  The additional information providers need to submit by February 15 includes:

  • From the DFR:
    • Nursing Home Patients from Table 1
    • Average Number of Comorbid Conditions from Table 12
  • From the Medicare Cost Report (MCR)
    • Net Patient Revenues from Worksheet F-1
    • Total Provider Treatments from Worksheet C

DOH encourages submission earlier than February 15 if possible.  Submission after February 15 will disqualify a provider from 2019 Concurrent Review Applications.

The applicable pages from these reports, for each dialysis facility owned or operated in Washington State, and for any out-of-state facilities that may potentially be used as a comparable facility, should be emailed to fslcon@doh.wa.gov in PDF format.  Though not required, a cover page that identifies which facilities are included is strongly recommended.

If any of the data elements above (from any of the DFR, DFC, MCR, or QIP) are unavailable for any reason, an exemption request can be submitted until February 28, 2019.  Valid reasons for an exemption could include, but are not limited to, any of:

  • A facility has opened too recently and data has not yet been published
  • Volumes at the facility are insufficient to generate a score
  • A change of ownership has taken place and valid data under your ownership and control does not yet exist

Regardless of the reason for your exemption request, it must be clear that absence of data is not a result of failure to report to CMS, and you must provide any applicable documentation.

Call DOH CoN at 360-236-2955 if you have any questions.

*PS: See our Acronyms table at https://nwrnbulletins.wordpress.com/abbreviations/ if we ever use abbreviations you don’t recognize.

12/3 Nat’l Accreditation Application

CMS has announced in the Federal Register that Accreditation Commission for Health Care, Inc. has applied to be recognized as an approved national accrediting organization for ESRD facilities.  CMS is requesting comments about their application, with a deadline of December 3, 2018.  For details see https://www.federalregister.gov/documents/2018/11/02/2018-23925/medicare-and-medicaid-programs-accreditation-commission-for-health-care-inc-achc-for-approval-of-its.

NW16 WA CofN Quality Comparisons

Beginning January 1, 2018, Washington State DOH will include provider quality of care as a tie-breaker between competing applications for Certificate of Need that have otherwise met the basic CofN criteria.  The methodology for considering quality of care is described on pp.15-19 of https://www.doh.wa.gov/Portals/1/Documents/2300/2017/CoNkidneydialysis103.pdf.

New CMS Fire Guidelines

CMS has proposed new fire protection guidelines for dialysis facilities.  Public comment is solicited until January 3, 2017.  It updates reference to the National Fire Protection Association Life Safety Code to the 2012 edition, and addresses construction, protection, and operation of dialysis facilities to provide safety for Medicare beneficiaries from fire and smoke.  Some of the primary requirements include self-closing doors to hazardous areas, location of alcohol based hand rub dispensers, provisions for when a sprinkler system is out of service, and requirements for facilities that do not have grade-level exits from the treatment area.  Find the proposed rule at ttps://www.gpo.gov/fdsys/pkg/FR-2016-11-04/html/2016-26583.htm and the CMS press release at https://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2016-Press-releases-items/2016-11-03.html .

SC 1/27 CA Dialysis Conference Exhibitor Registration Deadline

Online registration is now open for the for the March 2-4, 2017 California Dialysis Council’s Annual Educational Conference in Desert Springs CA.  Exhibitors must register by January 27, 2017.  Early registration discounts for attendees expire February 3, 2017.  The hotel registration deadline for group rates is February 8, 2017.  Planned topics for the Conference include hypertension, fluid control, facility ratings, Network 18 update, staffing shortages, common survey issues, HIPAA audits, new technology, and motivation.  For full details see http://www.californiadialysis.org/cdc-events/annual-conference.aspx .

NW 10/25 WA CofN Rule Comment Period

The Washington State Department of Health has published a Proposed Rule that modifies the way Certificate of Need applications for new dialysis facilities are evaluated.  Comments are due to WA DOH by October 25, 2016, and a public hearing will also be held on that date.  Find the Proposed Rule, hearing details, and comment form at https://fortress.wa.gov/doh/policyreview/Documents/1619038conkidney102final.pdf , and a Legislative Analysis of the Rule at https://fortress.wa.gov/doh/policyreview/Documents/slacertificateofneedkidneydialysis.pdf .