The Texas Department of Aging and Disability Services (DADS) issued a letter to provide clarification and notification to hospice agencies seeking initial Medicare certification of the current CMS survey and certification (S&C) requirements. Each year CMS publishes a Mission and Priority Document (MPD) that describes the S&C workload and program requirements for state agencies. The MPD describes how state agencies must prioritize S&C activities. The MPD includes guidance on the impact of hospices applying for initial certification. The MPD also has guidance for a currently certified hospice agency applying for certification of a multiple location or an inpatient unit. Under its agreement with CMS, DADS must schedule and conduct surveys per the S&C priority rankings set for in the MPD.
CMS Direction
The MPD contains four priority tiers for hospices (Tier I, II, III and IV) that reflect statutory mandates and program emphases. DADS must complete the S&C activities in Tier I, II and III before planning to complete Tier IV activities. Tiers I, II, and III include complaint surveys, validation surveys of deemed hospices, and routine surveys of non-deemed agencies. Initial Medicare certification surveys for hospices are a Tier IV priority because a hospice has the option to achieve deemed status (by demonstrating compliance with Medicare health and safety standards) through a survey conducted by a CMS – approved national accreditation organization (AO). Together with CMS, DADS prioritizes the workload within Tier IV and consults with the CMS Regional Office (RO) in the prioritizing process to ensure that the statutory requirements are met. The hospice is responsible for arranging the Medicare survey with the AO.
The MPD has special provisions for a priority exception request that is based on “access-to-care” problems. A hospice applying for initial Medicare certification may apply to CMS via DADS for an exception to the Tier IV priority assignment if the lack of Medicare certification would cause significant “access-to-care” problems for Medicare hospice beneficiaries.
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