Psychiatric Hospitals and Deemed Status

2044 - Psychiatric Hospitals and Deemed Status (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) Psychiatric hospitals have a Medicare accreditation option available to them. Prior to this being the case, however, CMS permitted a psychiatric hospital to have deemed status with respect to all hospital conditions (identified as “A” tags in ASPEN) except the special psychiatric CoPs at 42 CFR 482.60-62 (identified as “B” tags in ASPEN). Under this arrangement, the AO was responsible for assessing the psychiatric hospital’s compliance with all other hospital CoPs, i.e., those provisions with A tags, and either the SA or CMS’ contract surveyors assessed compliance with the special psychiatric CoPs, i.e., the B tags. Currently almost all deemed status psychiatric hospitals are accredited under the approved Medicare psychiatric hospital accreditation program, and their AO is responsible for assessing compliance under both the A and B tags. Any psychiatric hospital seeking initial participation in Medicare through deemed status must be accredited under a CMS-approved Medicare psychiatric hospital accreditation program. This also is the case for any non-accredited participating psychiatric hospital seeking to switch to deemed status. CMS no longer permits a psychiatric hospital to seek participation through deemed status for the A tags only. However, there are a small number of participating psychiatric hospitals that were deemed to meet the requirements for the A tags only prior to CMS approving a psychiatric hospital Medicare accreditation program. CMS considers these hospitals to have grandfathered deemed status for the A tags only, and SAs or CMS contract surveyors remain responsible for B tag surveys in these facilities. If a psychiatric hospital currently has deemed status for the A tags through accreditation by an AO which has a CMS-approved Medicare hospital accreditation program but does not have a CMS-approved Medicare psychiatric hospital accreditation program, and the psychiatric hospital wishes to be deemed for the special psychiatric hospital CoPs, it must seek accreditation from an AO with a CMS-approved Medicare psychiatric hospital accreditation program. In this instance, the psychiatric hospital may not choose to continue its current Medicare hospital accreditation with one AO in addition to obtaining its new Medicare psychiatric hospital accreditation with another AO; it must withdraw from its current Medicare hospital accreditation program and seek or maintain accreditation under a CMS-approved Medicare psychiatric hospital accreditation program only. It is not permissible for the psychiatric hospital to both be accredited by one AO under its hospital program and by another AO for the special psychiatric CoPs only. When the SA is responsible for surveying the special psychiatric CoPs of an otherwise deemed psychiatric hospital, the SA completes the Medicare/Medicaid Psychiatric Hospital Survey Data, Form CMS-724, and all other relevant survey documents (Form CMS-2567, etc.) for the survey.