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CMS Issues COVID-19 Related Changes to Survey Activities

The Centers for Medicare & Medicaid Services (CMS) issued Quality Safety & Oversight (OSQ) Memorandum QSO-20-12-All, Suspension of Survey Activities, on March 4, 2020.  In the QSO Memorandum background message, CMS stated that “Specifically, CMS is suspending non-emergency inspections across the country, allowing inspectors to turn their focus on the most serious health and safety threats like infectious diseases and abuse.  This shift in approach will also allow inspectors to focus on addressing the spread of the coronavirus disease 2019 (COVID-19). CMS is issuing this memorandum to State Survey Agencies to provide important guidelines for the inspection process in situations in which a COVID-19 is suspected.”

CMS directed that state agencies performing CMS surveys as well as all deemed authority Accreditation Organizations, must immediately modify their survey activities to the priorities listed within the CMS QSO-20-12-All memorandum.  The CMS survey priority list included the following:

  • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
  • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
  • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

Updated related CMS FAQs are being posted at https://www.cms.gov/medicare/quality-safety-oversight-general-information/coronavirus.

CMS is clearly closely following CDC guidance, and as a result the CMS and related survey emphasis on infection control could well include tracer-type activities related to maintaining required pressure relationships where both permanent and temporary patient care activities are in place.  As an example, the CDC page entitled “Interim Infection Prevention and Control Recommendations for Patients with Confirmed Coronavirus Disease 2019 (COVID-19) or Persons Under Investigation for COVID-19 in Healthcare Settings” includes the following:

“4. Implement Engineering Controls: Consider designing and installing engineering controls to reduce or eliminate exposures by shielding HCP (health care personnel) and other patients from infected individuals. Examples of engineering controls include physical barriers or partitions to guide patients through triage areas, curtains between patients in shared areas, closed suctioning systems for airway suctioning for intubated patients, as well as appropriate air-handling systems (with appropriate directionality, filtration, exchange rate, etc.) that are installed and properly maintained.”

There are many excellent resources to assist healthcare facilities professionals, including:

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