Ever feel like navigating the world of CMS changes is an uphill battle? You are not alone. Survey coordinators across the country face this challenge every day, and few have mastered the ability to track every major and minor change that comes from this government agency.
To help navigate this sometimes murky and often confusing task, we spoke with Sue Dill Calloway, RN, MSN, JD, director of hospital risk management for OHIC Insurance Company, The Doctor's Company, in Columbus, OH, who has provided her top five steps to track CMS changes.
Step One: Look at the hospital Conditions of Participation (CoP) Web site
"It's interesting—last year they weren't updating them at all, and the site was really outdated, and this year they've been posting [announcements] there first," says Calloway.
The hospital CoPs can be found online here: http://www.cms.hhs.gov/manuals/downloads/som107_Appendicestoc.pdf.
CMS itself provides the following instructions:
- Each Appendix is a separate file that can be accessed directly from the SOM Appendices Table of Contents, as applicable.
- The appendices are in PDF format, which is the format generally used in the IOM to display files. Click on the red button in the "Download" column to see any available file in PDF.
- To return to this page after opening a PDF file on your desktop, use the browser "back" button. This is because closing the file usually will also close most browsers.
Step Two: Visit your state survey and certification Web site
"This is the next place we tell hospitals they should go," says Calloway. "We've told everyone to go in once a month and check. [for updates]."
This page contains CMS survey and certification memoranda, guidance, clarifications and instructions to state survey agencies and CMS regional offices. It is searchable by date and keyword, as well.
The state survey and certification Web site can be found here: http://www.cms.hhs.gov/SurveyCertificationGenInfo/PMSR/list.asp#TopOfPage.
Step Three: Look at CMS transmittals
"They'll have transmittals that are just important issues," says Calloway.
According to the CMS Web site, program transmittals are used to communicate new or changed policies and/or procedures that are being incorporated into a specific CMS program manual. The cover page (or transmittal page) summarizes the new changed material, specifying what is changed.
The CMS transmittals page can be found here: http://www.cms.hhs.gov/transmittals/.
Step Four: The hospital center
"If you're working in a hospital setting, this is another good place to check for updates," says Calloway.
A quick check of recent updates to this page show that most of the announcements in 2009 have been related to payment systems, but other, more accreditation-related, changes are also announced here.
The hospital center page can be found here: http://www.cms.hhs.gov/center/hospital.asp.
Step Five: The EMTALA Web site
On this page, you will find changes and updates to regulations, manuals, and appendices, and also links back to transmittals related to EMTALA and EMTALA survey and certification letters. There is also a series of links with related and helpful material.
The EMTALA page can be found here: http://www.cms.hhs.gov/EMTALA/.