Medicare Compliance & Reimbursement

With new hospital quality rules in effect for Medicare, surveyors will be taking a different kind of look at how facilities take on enhancing patient care. In an April 10 letter to state survey agency directors (Ref: S&C-03-16), the Centers for Medicare and Medicaid Services outlines its expectations for compliance with the new quality assessment and performance improvement condition of participation for hospitals. The main purpose of the QAPI COP, CMS says, is to "set a clear expectation that hospitals must take a proactive approach to improve their performance and focus on improved patient care and patient safety, including the reduction and prevention of medical errors."

That means surveyors will expect hospitals to show, using objective data, that "improvement levels have taken place in actual care outcomes, processes of care, patient satisfaction levels, hospital operations, or other performance indicators."

CMS says that since hospitals already had to comply with a quality assurance COP prior to the advent of QAPI, a transition period to the new policy isn't needed - which means surveyors should have moved directly to checking for QAPI compliance as of March 25, 2003. CMS notes that interpretive guidelines are still in the works. However, interim guidance is available now - to see it, go to www.cms.gov/medicaid/ltcsp/sc0316.pdf. Lesson Learned: Hospitals should be ready now for surveyors to scrutinize compliance with the new QAPI measures, since CMS has decided against a transition period.