CMS and AO Information Exchange Regarding Deemed

1022 - CMS and AO Information Exchange Regarding Deemed Providers/Suppliers (Excluding CLIA) (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) Timely, accurate and complete information regarding deemed providers and suppliers must be shared between CMS and AOs with CMS-approved Medicare accreditation programs to ensure effective, ongoing oversight of AOs, as well as to ensure deemed provider/supplier compliance with applicable Medicare requirements. As part of CMS’ oversight of deemed providers and suppliers, AOs with CMS-approved Medicare accreditation programs are required to submit data and information concerning deemed facilities to CMS. Likewise, CMS is obligated to share pertinent information concerning facilities, as outlined in SOM sections 3256 and 5100.3. 1022A – AO Reporting Requirements (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) Under 42 CFR 488.4, AOs with CMS-approved Medicare accreditation programs are required to submit data concerning deemed Medicare providers/suppliers, including notices concerning current deemed status providers/suppliers as well as facilities recommended or not recommended for deemed status. To facilitate the timely receipt of such information from AOs an electronic process has been established for the AOs to submit reports and notices containing accreditation information regarding these facilities to CMS Central Office and the applicable RO. Eleven electronic mail boxes have been established; one for CMS CO and one for each of the ten CMS ROs. The Reports and Notices that AOs are required to forward through the electronic mailboxes are noted below: Types of Documents Central Office Email Box Regional Office Email Box Reports Monthly Adverse Action Report X Notices Accreditation Status of Facilities Recommended for Deemed Status (includes both initial and re- accreditation surveys) • Full Accreditation • Conditional Accreditation • Provisional Accreditation • Denial of Accreditation X X Termination/Withdrawals includes • Involuntary (AO-initiated) – as a result of CoP/CfC deficiencies, AO standard deficiencies, AO non-payment, closure or other AO policies. • Voluntary (Facility-Initiated) – change to State Agency or other AO merger, acquisition, or closure. Include reason for involuntary and voluntary terminations/withdrawals and last deemed X X Types of Documents Central Office Email Box Regional Office Email Box survey date Other Issues Email boxes may be used to transmit other documents that CMS requests in specific cases or that the AO wants to bring to CMS’ attention, e.g., resolution of deficiencies notices X X Required Content of AO Notification Letters to CMS Purpose: • To recommend or not recommend initial deemed status for the purpose of Medicare certification; • To recommend continued deemed status for the purpose of Medicare certification; • To provide notice of change in accreditation status, including but not limited to terminations, withdrawals, and changes resulting from sales or acquisitions; • To provide the status of oversight efforts to correct noncompliance with Medicare CoPs. Notice must be sent to CMS, both to CO and the applicable RO, via the electronic mail box at the same time that the provider/supplier is notified of the AO decision/action. Scanned copies with signature of the AO’s authorized representative are preferred. Required Information - All Final Accreditation Decision Letters: • Name of AO; • Date of notice; • Program type (i.e., the type of provider or supplier being accredited, such as ASC, CAH, HHA, Hospice, Hospital, OPT, Psychiatric Hospital or RHC); • Provider/Supplier name, address, and, if already enrolled in Medicare, CCN; • For providers/suppliers with multiple locations covered under one Medicare agreement – names and addresses for each location; • AO organization/facility number, if utilized; • Identification of applicable CMS RO (e.g.; RO I – Boston, RO IV – Atlanta, etc.); • Type of survey – initial, re-accreditation, complaint, revisit, extension or other; • Beginning and ending date of survey; • Accreditation decision: conditional, full accreditation, denial, etc.; • Effective date of accreditation, accreditation expiration date; • Whether or not the AO is recommending continuing deemed status; • For other than initial surveys, list only Medicare Condition-level deficiencies and include the corresponding CFR citation(s) that have been corrected based on completion of a focused follow up survey; • When applicable, whether an existing accreditation status is being extended to a newly acquired component of the provider, with time period for which accreditation is being extended; • Timeframe for plan of correction; and • Method of follow up – (multiple may apply) document review, full or focused follow up survey NOTE – An accreditation decision letter may apply only to one certified provider or supplier. In other words, the AO must make a separate accreditation decision for each separately certified provider or supplier and may not issue a system-level accreditation that applies to multiple providers or suppliers. Likewise, an accreditation decision letter must apply to the whole of a provider or supplier. For example, an AO may not issue an accreditation decision that applies to only one campus of a multi-campus hospital. Additional Required Information - Initial Medicare Enrollment Applicants: • The effective date of accreditation; • Whether or not the AO is recommending deemed status for the facility; and • The full, complete survey report containing all survey findings, including the deficiency(ies) as well as the evidence that supports the deficiency(ies), must be sent with the decision letter as an attachment. The RO reviews the AO survey findings as part of the Medicare certification review process. The RO is not obligated to accept the AO’s recommendation of deemed status if the RO determines that not all applicable Federal requirements have been met. If the RO determines that all Federal requirements have been met by the prospective provider/supplier, it issues a provider agreement or supplier approval and a CCN to the applicant, including the effective date of such agreement. The effective date of Medicare participation is determined by the RO based on the date when all Federal requirements have been met, which may be later than the effective date of the AO’s accreditation. Additional Required Information –Deemed Provider/Supplier Accreditation Renewals: • Whether or not the AO is recommending continued deemed status; and • Effective date of accreditation renewal. There must not be any break between this date and the expiration date of the previous accreditation. Additional Required Information – Deemed Provider/Supplier Withdrawals or Terminations: • Reason(s) for withdrawal or termination; • Withdrawals – reasons could include: acquisition, closure, merger, or withdrawal to SA authority. • Terminations – reasons could include: nonpayment of AO fees, failure to meet the accreditation program standards, or failure to satisfy other AO policies and procedures. • Date of most recent triennial accreditation survey; and • Effective date of termination or withdrawal. 1022B - RO Requirements for Review of AO Reporting (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) Each RO is responsible for review and appropriate follow-up action resulting from AO notices. To facilitate AO communication regarding Medicare deemed providers and suppliers, each RO has been assigned a CMS electronic mail (email) box dedicated to receiving notices from and sending communications to the AOs. Designated RO email box owners are responsible for maintaining and updating the access rights for the RO email box. Each RO develops policies and procedures for the management of its email box to ensure ongoing, timely review of AO notices, and timely follow-up actions, as necessary. 1022C - RO Reporting Requirements to AOs (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) The RO must provide the AOs with copies of every Form CMS 2567 issued to a deemed facility accredited by the AO(s) in a timely manner, i.e., as soon as possible after issuance to the provider/supplier. ROs have the option of sending this material to AOs electronically rather than mailing hard copies. Copies to be provided include all Form CMS 2567s resulting from a SA validation survey, including both representative sample and substantial allegation (complaint) surveys, as well as all Form CMS 2567s issued after the provider’s or supplier’s deemed status has been removed and the facility has been placed under SA jurisdiction until it can achieve substantial compliance. Copies of any correspondence sent to the provider or supplier related to a Form CMS 2567 must also be provided to the applicable AO(s), as well as correspondence concerning the status of the provider’s supplier’s Medicare provider agreement or supplier approval (e.g., issuance of an agreement/approval with CCN, notice of potential termination of the agreement/approval, notice of termination of the agreement/approval, etc.). Note that a provider or supplier may be accredited under a CMS-approved Medicare- accreditation program by more than one AO; in such cases all AOs must receive copies. See also Sections 3256 and 5100.2.