CMS is preparing to improve rules for Accrediting Organizations (AOs) that on contract survey healthcare facilities for Medicare Certification. They are requesting public comment on whether it should be considered a conflict of interest for an AO to also accept consulting fees from the corporation that’s opening the new facility. Comments are due by approximately February 18, 2019 (sixty days after publication of the RFI in the Federal Register, scheduled for December 20, 2018). The RFI is summarized at https://www.cms.gov/newsroom/fact-sheets/medicare-program-cms-requests-stakeholder-feedback-accrediting-organizations-conflict-interest-and. The proposed Federal Register text can be found at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-27506.pdf.
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.
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.
Kidney Care Partners (https://www.pr.com/press-release/744275) has summarized the ESRD-related provisions of the new budget law, H.R.1892 – Bipartisan Budget Act of 2018; the Act “will expand the use of home dialysis therapy through use of telehealth services; expedite patient access to quality dialysis care at newly certified facilities; and extend authority for Special Needs Plans (C-SNPs) without interruption in care.” In addition, payments for non-emergency ambulance use are reduced.
While the legislation as passed and signed may not be effective until HHS converts it to administrative law, the original lawyerese can be found at:
- For home health telehealth, https://www.congress.gov/bill/115th-congress/house-bill/1892/text#toc-HD17800AE048F430AB1B9EEFBB03FDD55.
- For newly certified units: “an initial survey of a … renal dialysis facility … shall be initiated not later than 90 days after such date on which both the provider enrollment form … [is] complete and the provider’s enrollment status indicates approval is pending the results of such survey,” https://www.congress.gov/bill/115th-congress/house-bill/1892/text#toc-H63740900ED184AAFA50F73B6BE696312.
- For continued access to Medicare Advantage special needs plans for vulnerable populations, https://www.congress.gov/bill/115th-congress/house-bill/1892/text#toc-H89926B550ADD45858E6C1A410176952E.
- For reduction of non-emergency ESRD ambulance transport payments, https://www.congress.gov/bill/115th-congress/house-bill/1892/text#toc-HC2CE8E0B05404D7CAB3E35F887FDC255.
The Greater Puget Sound Chapter #503 of ANNA will present their 2018 Renal Update February 1-2, 2018 in Lynnwood WA. Topics include incivility, surveys, iatrogenic death, teach-back, calciphylaxis, difficult conversations, passion and compassion, AKI, organ donation, ultrafiltration, lupus, hyponatremia, hyperoxaluria, and the future of dialysis. Registration is online only, and closes on January 29, 2018. Discounts are available until 11:30 pm PST January 10, 2018. For more information see https://s3-us-west-2.amazonaws.com/nwrn.org/files/N/ANNA/RenalUpdate2018.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/ .