New Condition Of Participation

by Expert Advice

New Condition Of Participation

by Expert Advice

by Expert Advice

In September, CMS issued a 198-page Federal Register announcement. In addition to new rules for nursing homes and laboratories, it includes a new Condition Of Participation (COP) for hospitals.

Condition Of Participation

CMS issued a press release on this same subject. It’s concise and easier to read than the 198 page document! Further, they issued two QSO memos to the nursing home industry explaining the new requirements in detail. Lastly, although we expect publication of a similar QSO memo applicable to the hospital industry, it has yet to occur.

But, we know the basics of what it will say from the Federal Register announcement. For example, laboratories will have to report the results of COVID-19 testing. Plus, hospitals will have to report data including:

  • Bed availability and utilization rates for COVID-19 patients
  • Equipment availability for items such as PPE and ventilators

You can access Federal Register data elements here.

The requirement for hospitals to report data will be at a COP level.

Further, on August 26, CMS issued two additional QSO memos. QSO-20-37 discussed required reporting of COVID-19 test results for CLIA certified laboratories. QSO-20-38 discusses new infection control requirements as well as mandatory testing of staff and residents in nursing homes. The second memo includes an attachment which is an updated version of the CMS COVID-19 Focused Survey Tool.

This tool includes recommended observation techniques for the CMS surveyor to assess compliance with infection control practices for COVID-19. Download the tool and consider the techniques used by CMS surveyors to observe staff and patient practices. If you’d like to read the QSO 20-38 memo you may access it through this link.

Patton Healthcare Consulting

Patton Healthcare Consulting can help you navigate the new normal. Our new remote consultation “Comprehensive Hybrid Readiness Review” is a hybrid remote/onsite support program. It is designed to assist with assessment and education to meet your needs going forward after this national emergency.

In addition, we understand the need for assistance without disrupting your organization or extensive costs. That’s the specific purpose of this program.  Contact us at (888) PHC-INC1 for more information or email us at


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