Articles and Blogs

On January 13, 2017, CMS published the revised Conditions of Participation (“CoPs”) for home health agencies, 42 CFR 484, Subparts A, B, and Subpart C. The CoPs became effective on January 13, 2018. On August 31, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum to State Survey Agency Directors (QSO-18-25-HHA) that... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) released a draft of the Interpretive Guidelines (“Draft Interpretive Guidelines”) to the final Conditions of Participation (“CoPs”) for home health agencies that CMS issued in January 2017. The CoPs are scheduled to be implemented January 13, 2018. CMS has asked for feedback on the Draft Interpretive Guidelines. The Draft... READ MORE

On June 16, 2017, CMS issued transmittal S&C: 17-35-ALL. This transmittal clarified CMS policy by stating a reasonable assurance period will apply if a provider or supplier voluntarily terminates its Medicare certification when an enforcement action has been initiated by the State Survey Agency. Section 2016 of the State Operations Manual allows a provider... READ MORE

On July 22, 2016, the Center for Clinical Standards and Quality/Survey & Certification Group released a memorandum that revised Chapter 7 of the State Operations Manual (“SOM”) and provided guidance on its policy to immediately impose federal remedies when a deficiency of a certain type is cited. The remedies are in addition to a... READ MORE

On August 2, 2013, the Centers for Medicare and Medicaid Services (“CMS”) issued an update to the State Operations Manual (“SOM”) regarding the process for notification of a facility closure.  The updates to the SOM are the result of a final rule published in the Federal Register on March 19, 2013 and can be... READ MORE

On September 27, 2012 CMS issued revised feeding tube interpretive guidelines to the State Operations Manual (“SOM”). While the actual federal regulation did not change, the SOM changes the interpretive guidelines, which can be found in Appendix PP of the SOM. READ MORE

On September 27, 2012, CMS issued an advance copy of the State Operations Manual (“SOM”) revisions to Appendix P of the SOM, which addresses Long-Term Care Facility survey protocol. The SOM guidance also makes changes to various survey forms resulting from the new quality measures reports. READ MORE