CMS and The Joint Commission recently issued a string of notifications to the healthcare industry in response to the novel COVID-19 Coronavirus outbreak. This blog post will cover the highlights of their updates, however we recommend that you visit the CMS and Joint Commission website for the full communication.
The Joint Commission
In its March 9, 2020 communication, the Joint Commission communicated that it is restricting travel for its surveyors away from impacted communities and hospitals in “disaster mode.” It also emphasized that surveys that do take place will focus in large part on COVID-19 preparedness and adoption of CDC and other recommendations.
- Breaking Joint Commission News March 17th, 2020: Today the Joint Commission announced the immediate suspension of regular surveys, leaving the door open to surveys stemming from “high risk situations” (undefined). Please visit the Commission’s online portal for your organization and their web site at https://JointCommission.org for this and other official communications. Your account representative remains the best resources for specific questions about your accreditation status.
Between March 4th and March 10th, 2020 CMS issued nine separate directives addressing:
- “Suspension of Survey Activities” (March 4),
- “Guidance for Infection and Prevention Concerning Coronavirus Disease (COVID-19): FAQs and Considerations for Patient Triage, Placement and Hospital Discharge” (March 4),
- “Emergency Medical Treatment and Labor Act (EMTALA) Requirements and Implications Related to Coronavirus Disease 2019 (COVID-19)” (March 9),
- “Guidance for the use of Certain Industrial Respirators by Health Care Personnel” (March 10), and separate guidance documents for nursing homes, chronic dialysis facilities, home health agencies, and hospice agencies.
Reprioritization of CMS survey activity
The communication to State survey agencies on March 4th, 2020 (QSO-20-12-All) put routine CMS surveys on hold. However, CMS will continue to authorize high priority surveys, such as complaints alleging immediate jeopardy, initial certifications and unresolved Medicare enforcement activities.
- Summary of CMS Survey priorities during COVID-19: Investigation of Complaints Alleging Jeopardy
- Investigation of Compliance Relating to COVID-19
- Recertification of Time-restricted Certification Agreements (e.g. SNFs)
- Some provider/supplier types, such as nursing homes, are only certified until a certain date. If the State Agency does not process the re-certification survey by the expiration date, the provider/supplier doesn’t get paid.
- Revisits Necessary to Abate Uncorrected Deficiencies
- If a non-compliance has been cited then it must be re-surveyed or otherwise abated. Known non-compliant conditions cannot linger.
- Initial Certifications
- CMS does not want to be the limiting factor on the availability of healthcare providers within the community.
- Hospitals with Immediate Jeopardy Related to Infection Prevention Within the Last 3 Years
- Hospitals with a History of Deficiencies Related to Infection Prevention (Non-Immediate Jeopardy)
Remember, however, that State licensing agencies (those that perform CMS surveys) typically have their own set of priorities. Sometimes State Agencies send surveyors out to all hospitals to check on readiness during community-wide emergencies.
EMTALA and COVID-19
The March 9th, 2020 communication (QSO-20-15-Hospital/CAH/EMTALA) explored the nuances of EMTALA compliance during the pandemic. The lengthy communique covers EMTALA basics but emphasized the following:
- Emergency departments are expected to follow current CDC guidelines to screen for potential COVID-19 infections.
- Hospitals must accept higher-level-of-care transfers if they have the current capability and capacity to care for the patient. We were reminded that COVID-19 patients do not require negative-pressure, respiratory isolation rooms.
- Patients may be directed by signs or clinical personnel to locations outside the emergency department for respiratory illness screening. Care must be taken, however, not to erect barriers to the medical screening of patients in the main emergency department when indicated. Additional caveats apply when the alternate location is “off campus.”
Infection Control Guidelines
The CMS memos hit the highlights of the extensive (and changing) CDC guidelines and emphasized the following:
- Alternatives may be used when the ideal personal protective equipment (e.g. N95 masks) is not available due to supply chain issues. (One communication alerted the field that OSHA and the FDA have issued a waiver for the use of industrial respirators in the healthcare setting during the outbreak.)
- Transmission-based precautions do not call for negative-pressure rooms except during “aerosol-producing procedures.”
- Telephone triage is encouraged when patients call ahead for advice.
- Upon arrival, cough etiquette and hand hygiene should be encouraged and supported; symptomatic patients should wait in an area separate from other waiting patients; and signs, flow control, and physical barriers should be used to reduce exposure when indicated.
- Environmental infection control principles should be followed, including waiting for the room air to clear droplet nuclei before terminal cleaning.
- Visitors should be passively screened (self-screened via signs) and use appropriate transmission-based precautions. When community-acquired COVID-19 infections are apparent, visitor screening and protection should become active (supervision by staff members).
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