On January 13, 2020, CMS announced it will change its survey process for psychiatric hospitals. Certainly, this is a significant change so it’s important to understand all the details.
New CMS Survey Process: What will be Different?
The key difference is how the State Survey Agency (SSA) will survey psychiatric hospitals. Effective March 2020, the SSA will review psychiatric hospitals for compliance with both Appendix A Hospital Conditions of Participation (CoPs) and Appendix AA Special CoPs for Psychiatric Hospitals.
The current process is that deemed status psychiatric hospitals undergo two separate surveys. One is the survey by the SSA for compliance with Appendix A (Hospital CoPs.) The other is the survey by an external contractor for compliance with Appendix AA (Psychiatric Hospital CoPs.)
Note: Appendix AA is also referred to as the “B Tags” since the standards are numbered B98 – B158.
New CMS Survey Process: Why the Change?
The change to a single survey process for psychiatric hospitals is part of CMS’ initiative titled “Patients Over Paperwork.” This initiative is aimed at reducing burdensome regulations on the healthcare industry.
So, the change to a single survey process should be more efficient. However, CMS will need to ensure the SSA surveyors are fully proficient in the B Tags.
The contracted surveyors who have done the B Tags up until now are psychiatrists and psychiatric nurses experienced and proficient in evaluating psychiatric hospitals. CMS is discontinuing the use of this separate federal contract organization.
The SSA surveyors often don’t have psychiatric hospital experience. CMS plans to train them in how to evaluate compliance with Appendix AA.
Impact on Joint Commission Survey Process
To clarify, the new CMS survey process does not impact the Joint Commission survey process. TJC will continue to conduct its deemed status surveys of psychiatric hospitals as they currently do. They use an integrated approach and evaluate compliance with both Appendix A and Appendix AA during deemed status surveys of psychiatric hospitals. TJC sent a letter to accredited psychiatric hospitals on January 17th to explain the change to the CMS survey process. It also confirmed there will be no change to the TJC survey process for psychiatric hospitals.
Barrins & Associates Updates and Resources
We’ll continue to update you on this new CMS survey process as it unfolds. In addition, we can support your ongoing CMS compliance with our CMS Compliance Support Services. We offer CMS Compliance Training, CMS mock surveys, and consultation on integrating CMS and TJC requirements for psychiatric hospitals.