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The QIOs monitor compliance with infection control standards and practices in the nursing home. Training can include working with staff on proper use of personal protective equipment (PPE), cohorting residents appropriately and transferring residents safely. The memo did include some non-punitive actions by CMS as they leveraged the Quality Improvement Organizations (QIOs) to assist nursing homes in combating COVID-19 through such efforts as education and training, creating action plans based on infection control problem areas, and recommending steps to establish a strong infection control and surveillance program. These funds would then be redistributed to those States that completed 100% of their focused infection control surveys by July 31. Subsequent 30-day extensions could result in an additional reduction up to 5%. After the 30-day period, if States have still not achieved surveys in 100% of their nursing homes, their CARES Act FY2021 allocation may be reduced by up to 10%.
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States that have not completed 100% of their focused infection control nursing home surveys by July 31, 2020, will be required to submit a corrective action plan to their CMS location outlining the strategy for completion of these surveys within 30 days. CMS clearly indicated in the memo that states needed further direction to prioritize completion of focused infection control surveys in nursing homes. However, the completion variability across states, ranging from 11-100%, certainly did not meet CMS’ expectations for the state survey agencies. I can’t help but wonder if this is akin to kicking someone when they’re down.įifty-three percent of the nation’s nursing facilities have experienced a Focused Infection Control survey. Compliance concerns, lower than expected focused survey completion rates, and results from the federal reporting requirements prompted CMS to take an aggressive approach in its guidance. CMS’ concerns about provider compliance with infection control practices is certainly not new, however, the emergence of COVID-19 certainly elevated that concern due to the serious threat to resident health and safety. The memo also reinforced their expectations for state survey agencies and the timely completion of infection control focused surveys. CMS announced plans for expansion of enforcement activities to improve provider accountability and sustained compliance of infection control practices in a June 1 CMS Memo.