Beginning
on October 1, 2013, every CMP that is imposed by CMS will be subject to the
escrow provisions and the nursing facility may request Independent IDR on any
level deficiency. On and after October 1, 2013, there will no longer be
any restriction on what level deficiency a facility can request Independent IDR
when CMP has been issued on that deficiency. The offer of Independent IDR
will be communicated in the CMP notice letter. CMS will collect the CMP
on the earlier of the two dates described above.
This
change in policy will only apply to standard and complaint surveys that begin
on or after October 1, 2013. Any revisit survey conducted on or after
October 1, 2013 that is associated with a standard or complaint survey
completed before October 1, 2013 will not be subject to this new policy
change. To read the CMS memorandum discussing this change, click here.
If
you have additional questions on Independent IDR Participation please contact
Meghan McNab at mmcnab@kdlegal.com or
Zach Cattell at zcattell@kdlegal.com.