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Posted Aug 18, 20204 min Read
On August 17, 2020, the Centers for Medicare and Medicaid Services (CMS) issued QSO 20-35 to state survey agency directors, instructing them to return to their normal survey process as soon as resources in the state allow and in accordance with each state’s reopening plan. The memorandum also provides guidance to states on how to resolve pending enforcement actions suspended as a result of prior QSO memorandums. IHCA will be meeting with ISDH this week to discuss the department’s interpretation of and plans to implement this CMS directive.
Specifically, on March 23, 2020, CMS issued QSO 20-20, which limited survey activity to focused infection control surveys. On June 1, 2020, CMS issued QSO 20-31, which provided survey re-prioritization guidance to transition to more routine oversight and survey activities. This latest memorandum instructs states to restart all normal surveys, as feasible, and IHCA/INCAL is actively working with the Indiana State Department of Health (ISDH) to understand their plans for implementation of QSO 20-35.
As outlined in QSO 20-35, CMS intends to resolve suspended enforcement cases and provided guidance for closing them out going forward. This process involves four components:
CMS also issued updated guidance for the re-prioritization of routine Clinical Laboratory Improvement Amendments (CLIA) survey activities, subject to the state survey agency’s discretion, in addition to lifting the restriction on processing CLIA enforcement actions and issuing the Statement of Deficiencies and Plan of Correction (Form CMS-2567) for CLIA citations.
We encourage you to review the entirety of QSO 20-35, and we will update you when ISDH provides further guidance regarding its implementation. Questions for CMS on a specific enforcement cycle may be directed to: DNH_Enforcement@cms.hhs.gov.