There are new steps you need to take if you lose deemed status. Perspectives announces a new APR 01.03.01, EP 2 that takes place effective July 1, 2018.
Deemed Status Removal
Do you remember the Wall Street Journal article last year criticizing the Joint Commission? It was because TJC continued to show organizations as fully accredited even after deemed status removal which was out of sync with CMS information.
Part of that disparity was TJC not hearing from CMS when they make these decisions. Well, this new APR will eliminate the problem. As of July 1, if you have a CMS survey and CMS temporarily removes deemed status, requiring clearance
by the state agency, you will have to notify TJC. The EP states that when you receive such notice from CMS you must immediately notify TJC. The term immediately is not defined. But, it is your best interest to do it that same day.
TJC indicates that it will not perform routine resurveys if your deemed status has been removed. CMS in their memo QSO 18-12 issued January 12, 2018 stated the following:
“No accreditation decisions or recommendations made by an AO based on a Medicare accreditation survey conducted while a supplier or provider is under state agency jurisdiction will be accepted by CMS.”
Inform The Joint Commission
What happens if the Joint Commission does not hear about the deemed status removal and the surveyors show up at your door?
- If you inform them about deems status removal, TJC won’t complete the survey and they will charge for it.
- If you don’t inform them and they conduct the survey, it appears that CMS will not accept the results. Plus, you will have to go through another survey after returning to deemed status.
The Joint Commission asks that you notify your Account Executive via email should you receive this notice from the CMS. And, make sure you keep a copy. In the event a survey gets scheduled and there is a billing dispute, you’ll have documentation.
If you need Joint Commission compliance assistance or could benefit from mock surveys to prepare for upcoming TJC and CMS interactions, contact us for additional information.