Objectives of RO Certification Review

2778 - Objectives of RO Certification Review (Rev. 123, Issued: 10-03-14, Effective: 10-03-14, Implementation: 10-03-14) The primary objective of the review is to assure that the certification, together with other documents, is adequate evidence of the identity of the certified institution and of its conformance to the laws and regulations governing program participation. Since the RO certification specialist must process various request forms and notifications and assure that the documentation is complete, it is of paramount importance that the specialist perform a quality-oriented appraisal. Before approving participation, the RO must be certain that the SA’s certification of compliance is consistent with the documented findings. The RO considers the impact of deficient standards, elements, or Requirements (for SNFs and NFs) on the respective CoPs or Requirements; the provider’s deficiency history profile; recent beneficiary complaints; or other external reports justifying further documentation of a provider’s practices and consults with RO health professionals when appropriate. Other objectives are accomplished by this review. The RO decides whether it agrees with the SA recommendation of compliance or noncompliance and its interpretation of reasonable time and reasonable plans for the correction of deficiencies and waivers. The RO reviews the Statement of Deficiencies and Plan of Correction, Form CMS-2567, to ensure that the SA’s documentation supports the SA certification recommendation, acceptable plan of correction (PoC), or waiver request. The RO notes the timeliness and quality of SA processing, and extract information relating to administrative or program problems that the case reveals so that identified program problems can be corrected on the regional or national level. In the case of hospitals that participate in both Medicare and Medicaid or Medicaid-only or of Critical Access Hospitals (CAHs), the RO must ensure the completion of the Hospital/CAH database worksheet (Exhibit 286) by the SA for all certifications, including initial certifications, regardless of whether the survey was conducted by the SA or AO. The survey kit will not upload without completion in ASPEN of the worksheet. In Medicaid-only cases, the SA certifies its determination as to the provider’s compliance with the participation requirements. With the exception of PRTFs, the SMA must accept certification determinations as final and may not enter into a provider agreement with a NF, HHA, hospital or ICF/IID unless the SA has certified the provider as in compliance with applicable requirements for program participation. It may, however, for good cause, refuse to execute an agreement with a NF, HHA, hospital or ICF/IID certified by the SA. (See 42 CFR 442.12(d).) Certification documents are official statements of the SA that may not to be altered. The RO uses the Request for Additional Information, Form CMS-1666 (Exhibit 15), to request additional information or documentation. (See §2776.) If a deficiency is subsequently corrected, the corrective action will be shown on Form CMS-2567 or the Post-Certification Revisit Report, Form CMS-2567B, as appropriate. If the deficiencies have not been corrected at the time of the revisit, they are shown on a new Form CMS-2567. The CASPER system accumulates data on the ability of providers and suppliers to meet program participation requirements at the time of the survey. CASPER data from Form CMS-2567 and Form CMS-2567B are used to measure the extent of progress providers and suppliers make in complying with program requirements. In case of an unreconciled interpretive disagreement with the SA, the RO can arrive at a determination disagreeing with the SA, provided there is evidence to support a contrary decision. If the RO disagrees with the SA certification, it justifies its rejection in writing and attempts to resolve the disagreement. If necessary, a disagreement over interpretive policy can be referred to CMS CO for resolution.