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Critical Access Hospital CoP Update

October 10th, 2016

Critical access hospitals (CAH) should be aware of an important survey memo published by CMS on Jan. 16, 2015. This is an advance memo to provide extra time for CAHs to review before it becomes final.

CMS reserves the right to make changes or tinker with the changes. When the changes are final, CMS will publish a transmittal and then update the CAH manual. The current manual is dated October 10, 2014. The CAH manual is located under Appendix W at http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107_Appendixtoc.pdf

The Jan. 16 survey memo can be found here. This 93-page memo changes many changes. The sections on rehabilitation, nursing, drugs and biologicals, pharmacy, dietary, and infection control were completely rewritten. There has been a section added on IV medication, blood, contract management, and safe opioid use.

Many of these changes may look familiar to larger hospitals with many similarities noted in the Appendix A manual. This may be good news to hospitals in systems as the manuals will be more closely cross walked. It will make it a little easier for hospitals in system to adopt policies and procedures. It will also be easier for the CMS surveyors since there will be less differences between the two manuals.

The survey memo also provides the final interpretive guidelines for three changes that became effective July 11, 2014. CAHs no longer need an outside person to be a member of the hospital’s policy and procedure committee.

There is no longer a requirement that a physician, such a MD or DO, be present in the hospital at least once every two weeks. Some of the larger CAHs may have 25 patients, observation patients, and an active outpatient department and may have physicians present on a daily basis. The CAH just needs to ensure that the physicians are present for sufficient periods of time to provide medical direction.

The third section addressed the issue of when a physician had to review the outpatient orders of a non-physician practitioner such as a nurse practitioner or a physician assistant. A physician would only need to co-sign outpatient orders to the extent required under state law if there is a state law that requires such a review and co-signature.

Every CAH should take a look at the Jan. 16 memo. Hospitals should assemble a team to review the standards and do a gap analysis. Hospitals should start working on revised policies and education that will need to take place. Hospitals should watch for the final revisions by monitoring the CMS manual website so that all CAHs are aware of when these advanced changes are final.