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CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** This tool has been developed the Montana Rural Healthcare Performance Improvement Network (PIN) to assist in preparing for a survey. This document refers only to Quality Assurance tags that are supported by the PIN. This tool will be updated with each revision to the SOM. Tags with the most recent revisions (April 2015) are noted on the index with an asterisk (*). As of the October 2016 revisions, there have not been updates to QA tags. For more details on each measure, you may view the CAH State Operations Manual (SOM) at the following link: http://www.cms.gov/Regulations-and-guidance/Guidance/Manuals/Downloads/som107ap_w_cah.pdf INDEX ☐C-151: Compliance with Federal Laws & Regulations ......................................................... 3 ☐C-160: Condition of Participation: Status & Location .......................................................... 3 ☐C-165: Location Relative to Other Facilities or Necessary Prov. ..................................... 3 Agreements ................................................................................................................................. 4 ☐C-195: Agreements for Credentialing & Quality Assurance............................................... 4 ☐C-196: Agreements for Cred/Priv of Telemedicine Providers ......................................... 5 ☐C-197: Agreements for Cred/Priv of Telemedicine Physicians and Practitioners .... 7 Provider Responsibilities ...................................................................................................... 9 ☐C-257: Responsibilities of the MD/DO (b)(1)(i) ..................................................................... 9 ☐C-258: Responsibilities of the MD/DO (b)(1) (ii) .................................................................. 9 ☐C-259: Responsibilities of the MD/DO (b)(1) (iii) .............................................................. 10 ☐C-260*: Responsibilities of the MD/DO (b)(1) (iv) ............................................................ 10 ☐C-261*: Responsibilities of the MD/DO (b)(2)..................................................................... 11 ☐C-263: PA, NP, and Clinical Nurse Specialist Responsibilities(c)(1)(i) ...................... 12 ☐C-264: PA, NP, and Clinical Nurse Specialist Responsibilities(c)(1)(i) ...................... 12 ☐C-265: PA, NP, and Clinical Nurse Specialist Responsibilities(c)(2)(i) ...................... 13 ☐C-267: PA, NP, and Clinical Nurse Specialist Responsibilities(c)(2)(i) ...................... 13 ☐C-268: PA, NP, and Clinical Nurse Specialist Responsibilities(c)(3) ........................... 14 Patient Care Policies ............................................................................................................. 14 ☐C-271*: Patient Care Policies (a) ............................................................................................... 14 ☐C-272*: Patient Care Policies (a)(2) ......................................................................................... 15 ☐C-273*: Patient Care Policies (a)(3)(i) .................................................................................... 16 ☐C-274*: Patient Care Policies (a)(3)(ii) ................................................................................... 16 ☐C-275*: Patient Care Policies (a)(3)(iii) ................................................................................. 17 ☐C-276*: Patient Care Policies (a)(3)(iv).................................................................................. 18 ☐C-277*: Patient Care Policies (a)(3)(v) ................................................................................... 22 ☐C-278*: Patient Care Policies (a)(3)(vi).................................................................................. 23 1 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** ☐C-279*: Patient Care Policies (a)(3)(vii) ................................................................................ 24 Patient Services ...................................................................................................................... 26 ☐C-281*: Patient Services ............................................................................................................... 26 ☐C-282*: Laboratory Services ....................................................................................................... 27 ☐C-283*: Radiology Services.......................................................................................................... 28 ☐C-285: Services Provided Through Agreements or Arrangements ............................. 30 Patient Visitation Rights ..................................................................................................... 31 ☐C-1000: Patient Visitation Rights (f) ........................................................................................ 31 ☐C-1001: Records System ............................................................................................................... 31 ☐C-1002: Patient Visitation Rights (f) ........................................................................................ 32 Surgical Services .................................................................................................................... 32 ☐C-320: CoP Surgical Services ....................................................................................................... 32 State Exemption ..................................................................................................................... 34 ☐C-326: State Exemption ................................................................................................................ 34 Periodic Evaluation & Quality Assurance Review ...................................................... 35 ☐C-330: CoP Periodic Evaluation and QA Review ................................................................. 35 ☐C-331: Periodic Evaluation (a)(1) ............................................................................................. 35 ☐C-332: Periodic Evaluation (a)(1)(i) ........................................................................................ 35 ☐C-333: Periodic Evaluation (a)(1)(ii)....................................................................................... 36 ☐C-334: Periodic Evaluation (a) ................................................................................................... 36 ☐C-335: Periodic Evaluation (a)(2) ............................................................................................. 37 ☐C-336: Quality Assurance (b) ...................................................................................................... 37 ☐C-337: Quality Assurance (b)(1)................................................................................................ 38 ☐C-338: Quality Assurance (b)(2)................................................................................................ 39 ☐C-339: Quality Assurance (b)(3)................................................................................................ 40 ☐C-340: Quality Assurance (b)(4)................................................................................................ 41 ☐C-341: Quality Assurance (b)(5)(i)........................................................................................... 43 ☐C-342: Quality Assurance (b)(5)(ii) ......................................................................................... 44 ☐C-343: Quality Assurance (b)(5)(iii) ........................................................................................ 45 Organ, Tissue & Eye Procurement ................................................................................... 45 ☐C-345: CoP Organ, Tissue, & Eye Procurement.................................................................... 45 Swing-Beds ............................................................................................................................... 47 ☐C-350: Special Req. for CAH providers of LTC Services (Swing-Beds) ....................... 47 2 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0151 §485.608(a) Standard: Compliance with Federal Laws and Regulations Each CAH must be in compliance with applicable Federal laws and regulations related to the health and safety of patients. This includes other Medicare regulations and Federal laws and regulations not specifically addressed in the CoPs. State Survey Agencies are expected to assess the CAH’s compliance with the following Medicare provider agreement regulation provisions when surveying for compliance with §485.608(a). C-0160 §485.610(a) Standard: Condition of Participation: Status & Location (Rev. 84, Issued: 06-07-13, Effective: 06-07-13, Implementation: 06-07-13) The CAH must meet the location requirements of §485.610(b) and §485.610(c) at the time of the initial survey. Compliance with these location requirements must be reconfirmed at the time of every subsequent full survey. If the CAH moves, its eligibility for continued CAH status must be reassessed in accordance with §485.610(d). C-0165 §485.610(c) Standard: Location Relative to Other Facilities or Necessary Provider Certification (Rev. 84, Issued: 06-07-13, Effective: 06-07-13, Implementation: 06-07-13) A CAH that can document that it was designated by a State as a necessary provider CAH prior to January 1, 2006, does not have to meet the location relative to other facilities standard at §485.610(c). As of January 1, 2006, States do not have the authority to designate any new necessary provider CAHs. Necessary provider CAHs that were designated prior to that date are grandfathered by statute, subject to certain conditions if they relocate. ROs and SAs should have the documentation related to a CAH’s original designation as a necessary provider in the file on each CAH. If they do not, they should ask the CAH to supply copies of the original necessary provider designation documents. Existing CAHs that are not grandfathered necessary provider CAHs must be periodically evaluated to determine whether there are any more recently certified Medicare-participating hospitals that are not more than a 35-mile drive, or 15- mile drive, as applicable, from the CAH. In the event that an existing CAH that is not a grandfathered necessary provider no longer meets the minimum distance requirement, it is provided the opportunity to avoid termination of its provider agreement by converting to a certified Medicare hospital after demonstrating compliance with the hospital CoPs. 3 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** CREDENTIALING AGREEMENTS C-0195 §485.616(b) Standard: Agreements for Credentialing and Quality Assurance Each CAH that is a member of a rural health network shall have an agreement with respect to credentialing and quality assurance with at least- One hospital that is a member of the network; One QIO or equivalent entity; or One other appropriate and qualified entity identified in the State rural health care plan. Note: The PIN is identified as such an entity in the State’s rural health plan. Self-Evaluation: Comments/Actions □ Yes □ No Was this a deficiency on your last survey? □ Yes □ No Does your facility have a written agreement with respect to credentialing and QA? _________________________ Where is it? _________________________ Who is the agreement with If you are using the PIN to meet this requirement, is your hospital participating in: □ Yes □ No PIN benchmarking or clinical improvement projects? □ Yes □ No PIN-sponsored networking meetings? □ Yes □ No Other PIN education opportunities? □ Yes □ No Have you had the PIN conduct an onsite credentials review? If so, where are the review findings? _________________________ □ Yes □ No Have you addressed them? 4 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0196 §485.616(b) Standard: Agreements for Credentialing & Privileging of Telemedicine Physicians and Practitioners A CAH may make arrangements with a distant-site Medicare-participating hospital for the provision of telemedicine services to the CAH’s patients by physicians or practitioners granted privileges by the distant-site hospital. If a CAH enters into an agreement for telemedicine services with a distant-site hospital, the agreement must be in writing. Furthermore, the written agreement must specify that it is the responsibility of the distant-site hospital to conduct its credentialing and privileging process for those of its physicians and practitioners providing telemedicine services such that the distant-site hospital: Self-Evaluation: Comments/Actions □ Yes □ No Are agreements for telemedicine services in writing for each distant-site hospital? □ Yes □ No Do the agreements specify that it is the responsibility of the distant-site hospital to conduct its own credentialing and privileging process for physicians and practitioners providing telemedicine services? Do the agreements include the following credentialing and privileging responsibilities of the distance-site hospital: □ Yes □ No Determines, which categories of practitioners are eligible candidates for privileges or membership on the distant-site hospital’s medical staff. □ Yes □ No Appoints members and grants medical staff privileges after considering the recommendations of the existing members of the distant-site hospital’s medical staff. 5 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Assures that the distant-site hospital’s medical staff has bylaws. □ Yes □ No Approves the distant-site hospital’s medical staff bylaws and other medical staff rules and regulations. □ Yes □ No Ensures that the medical staff is accountable to the distantsite hospital’s governing body for the quality of care provided to patients. □ Yes □ No Ensures the criteria for granting medical staff membership/privileges to an individual are the individual’s character, competence, training, experience, and judgment. □ Yes □ No Ensures that under no circumstances is the accordance of distant-site hospital medical staff membership or privileges dependent solely upon certification, fellowship or membership in a specialty body or society. If your hospital relies on the credentialing and privileging decisions of the distant-site hospital, does your agreement address the following? □ Yes □ No Distant-site hospital participates in the Medicare. □ Yes □ No Distant-site hospital provides a list to the CAH of all privileged physicians and practitioners covered by the agreement, including their privileges at the distant- site hospital. □ Yes □ No Each physician or practitioner who provides under the agreement holds a license issued or recognized by the State where the CAH is located. □ Yes □ No CAH has evidence that it reviews the telemedicine services provided to its patients and provides feedback based on this review to the distant-site hospital for the latter’s use in its periodic appraisal of each physician and practitioner providing telemedicine services under the agreement. 6 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0197 §485.616(b) Standard: Agreements for Credentialing & Privileging of Telemedicine Physicians and Practitioners (3) The governing body of the CAH must ensure that when telemedicine services are furnished to the CAH’s patients through an agreement with a distant- site telemedicine entity, the agreement is written and specifies that the distant-site telemedicine entity is a contractor of services to the CAH and as such, in accordance with §485.635(c)(4)(ii), furnishes the contracted services in a manner that enables the CAH to comply with all applicable conditions of participation for the contracted services, including, but not limited to, the requirements in this section with regard to its physicians and practitioners providing telemedicine services. Self-Evaluation: Comments/Actions Do you have a written agreement with the distant-site telemedicine entity that includes requirements and ensures that the contractor fulfills these requirements? □ Yes □ No providing medical direction for the CAH □ Yes □ No provides consultation for health care staff? □ Yes □ No provides supervision of health care staff? Does the distant-site telemedicine entity do the minimum: □ Yes □ No Determine which categories of practitioners are eligible candidates for medical staff privileges or membership at the telemedicine entity; □ Yes □ No Appoint members and grant medical staff privileges after considering the recommendations of the existing members of its medical staff; □ Yes □ No Assure that its medical staff has bylaws; 7 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Approve its medical staff‘s bylaws and other medical staff rules and regulations; □ Yes □ No Ensure that the medical staff is accountable to the distantsite telemedicine entity’s governing body for the quality of care provided to patients; □ Yes □ No Ensure the criteria for granting distant-site telemedicine medical staff membership/privileges to an individual are the individual’s character, competence, training, experience, and judgment; □ Yes □ No Ensure that under no circumstances is the accordance of medical staff membership or privileges dependent solely upon certification, fellowship or membership in a specialty body or society. Does the written agreement include the following: □ Yes □ No The distant-site telemedicine entity provides to the CAH a list of all its privileged physicians and practitioners covered by the agreement, including their privileges at the distantsite telemedicine entity. □ Yes □ No Each physician or practitioner who provides telemedicine services to the CAH’s patients under the agreement holds a license issued or recognized by the State where the CAH is located. □ Yes □ No The CAH reviews the performance of the physicians and practitioners providing telemedicine services to its patients and provides a written review to the distant-site telemedicine entity for the latter’s use in its periodic appraisal of each physician and practitioner providing telemedicine services under the agreement. 8 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** PROVIDER RESPONSIBILITIES C-0257 §485.631 (b)(1) Standard: Responsibilities of the Doctor of Medicine or Osteopathy (i) Provides medical direction for the CAH’s health care activities and consultation for, and medical supervision of, the health care staff; Self-Evaluation: Comments/Actions Do the medical staff and governing board bylaws indicate a physician is responsible for: □ Yes □ No providing medical direction for the CAH □ Yes □ No provides consultation for health care staff? □ Yes □ No provides supervision of health care staff? C-0258 §485.631 (b)(1) Standard: Responsibilities of the Doctor of Medicine or Osteopathy (ii) In conjunction with the PA(s) and/or NP(s), participates in developing, executing, and periodically reviewing the CAH’s written policies governing the services it furnishes. Self-Evaluation: Comments/Actions □ Yes □ No 9 Is there documentation that demonstrates a physician has participated in developing, executing and annually reviewing the CAH’s medical care policies, procedures, clinical practice guidelines, etc? (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0259 §485.631 (b)(1) Standard: Responsibilities of the Doctor of Medicine or Osteopathy (iii) In conjunction with the PA(s) and/or NP(s), periodically reviews the patient records, provides medical orders, and provides medical services to the patients of the CAH; Self-Evaluation: Comments/Actions Is there documentation that a physician: □ Yes □ No periodically reviews CAH patient records in conjunction with staff mid-level practitioners; □ Yes □ No provides medical orders for CAH patients? □ Yes □ No provides medical services? C-0260 §485.631 (b)(1) Standard: Responsibilities of the Doctor of Medicine or Osteopathy (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (iv) The MD or DO periodically reviews and signs the records for all inpatients cared for by NP’s, clinical nurse specialists, or PA’s. Note: See the clarification released 6-9-05 from CMS for specific guidelines concerning the number/percent of midlevel inpatient and outpatients records to be signed by the physician in Montana CAHs (v) Periodically reviews and signs a sample of outpatient records of patients cared for by nurse practitioners, clinical nurse specialists, certified nurse midwives, or physician assistants only to the extent required under State law where State law requires record reviews or co-signatures, or both, by a collaborating physician. Self-Evaluation: Comments/Actions □ Yes □ No What sample size does your policy require to have MD/DO review of outpatient encounters? □ Yes □ No What time frame does your policy specify for reviews of outpatient encounters? 10 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No How do you ensure your sample is representative of various non-physician practitioners as well as various types of outpatient services? For inpatient records of patients whose care is/was managed by a nonphysician practitioner, is there documentation that a physician has: □ Yes □ No reviewed and signed all records open at the time of review? □ Yes □ No reviewed and signed all records closed since last review? □ Yes □ No has reviewed in the timeframe specified by the CAH’s policy? □ Yes □ No reviewed and signed at least 25% of outpatient and 100% of inpatient records of patients treated by a NP? □ Yes □ No reviewed and signed at least 25% of outpatient record and 100% of inpatients treated by a CRNA? C-0261 §485.631 (b)(2) Standard: Responsibilities of the Doctor of Medicine or Osteopathy (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) A doctor of medicine or osteopathy is present (being on-site) for sufficient periods of time to provide the medical direction, medical care services, consultation and supervision for services provided in the CAH, and is available through direct radio, telephone or electronic communication for consultation, assistance with medical emergencies or patient referral. Self-Evaluation: Comments/Actions □ Yes □ No Do you have policies and procedures that address minimum time and frequency of MD/DO presence on-site at CAH? □ Yes □ No Do policies reflect volume and type of services to determine there is sufficient MD/DO presence on-site to support these services? □ Yes □ No Where and what is the documentation showing a MD/DO is onsite for frequency and duration specified in CAH polices? 11 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Can you demonstration that a MD/DO is always available by telecommunications for consultation, et al? C-0263 §485.631 (c)(1) Standard: Physician Assistant, Nurse Practitioner and Clinical Nurse Specialist Responsibilities (i) Participate in the development, execution, and periodic review of the written policies governing the services the CAH furnishes; Self-Evaluation: Comments/Actions □ No Mid-Levels - N/A □ Yes □ No Is there documentation that mid-level providers have participated in the development, execution and annual review of policies, procedures, clinical practice guidelines, etc, governing CAH medical services? C-0264 §485.631 (c)(1) Standard: Physician Assistant, Nurse Practitioner and Clinical Nurse Specialist Responsibilities (i) Participate with a doctor of medicine or osteopathy in a periodic review of the patient’s health records. Self-Evaluation: Comments/Actions □ No Mid-Levels - N/A □ Yes □ No Is there documentation that the mid-level provider periodically reviews the records of CAH patients he/she has cared for in conjunction with the physician supervisor? 12 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0265 §485.631 (c)(2) Standard: Physician Assistant, Nurse Practitioner and Clinical Nurse Specialist Responsibilities. Performs the following services to the extent that they are not being performed by a doctor of medicine or osteopathy: (i) Provides services in accordance with CAH policies Self-Evaluation: Comments/Actions □ No Mid-Levels - N/A □ Yes □ No Is there documentation that the mid-level provider provides services in accordance with CAH policies? C-0267 §485.631 (c)(2) Standard: Physician Assistant, Nurse Practitioner and Clinical Nurse Specialist Responsibilities. Performs the following services to the extent that they are not being performed by a doctor of medicine or osteopathy: (i) Arranges for, or refers patients to, needed services that cannot be furnished at the CAH, and assures that adequate patient health records are maintained and transferred as required when patients are referred. Self-Evaluation: Comments/Actions Is there documentation that the mid-level provider provides services in accordance with CAH policies? □ No Mid-Levels - N/A □ Yes □ No arranges for needed services that cannot be furnished at the CAH? □ Yes □ No refers patients to needed services that cannot be furnished at the CAH? □ Yes □ No Assures that adequate patient records are maintained and transferred as when required when patients are referred? 13 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0268 §485.631 (c)(3) Standard: Physician Assistant, Nurse Practitioner and Clinical Nurse Specialist Responsibilities. Whenever a patient is admitted to the CAH by a NP, PA or clinical nurse specialist, a doctor of medicine or osteopathy on the staff of the CAH is notified of the admission. Self-Evaluation: Comments/Actions □ No Mid-Levels - N/A □ Yes □ No Is there documentation that the mid-level notifies a physician on staff at the CAH of patients who are admitted? PATIENT CARE POLICIES C-0271 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) The CAH’s health care services are furnished in accordance with appropriate written policies that are consistent with applicable State law. Self-Evaluation: Comments/Actions □ Yes □ No Is there written policies covering health care services furnished in the CAH? □ Yes □ No Can you ensure your staff is providing services consistent with the writing policies? 14 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0272 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (2) The policies are developed with the advice of members of the CAH’s professional healthcare staff, including one or more doctors of medicine or osteopathy and one or more physician assistants, nurse practitioners, or clinical nurse specialists, if they are on staff under provisions of §485.631 (a) (1). Policies are reviewed at least annually by the group described and as necessary by the CAH. A CAH with no non-physician practitioners on staff is not required to obtain the services of an outside non-physician practitioner to server on the advisory group. Self-Evaluation: Comments/Actions □ Yes □ No Does your policy advisory group include (required!) (1) at least one MD/DO (2) one or more PA, NP, or CNP if they are on staff. □ Yes □ No Is there documentation of physician involvement with the policy development group? □ Yes □ No Can you ensure all staff listed as part of the group has had the opportunity to express opinions and make recommendations? They will be interviewed. □ Yes □ No Is there documentation the advisory group developed written recommendations on the CAH patient care policies for consideration by the governing body or responsible individual? □ Yes □ No Is there documentation the group reviewed the CAH’s existing policies at least annually and indicated whether or not it recommended any changes? 15 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0273 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15 – grammar change only) (3)(i) The policies include a description of the services the CAH furnishes, including those furnished through agreement or arrangement. Self-Evaluation: Comments/Actions □ Yes □ No Is there a policy describing services the CAH furnishes directly and those furnished under a contract, informal agreement or lease arrangement? □ Yes □ No Is there evidence that all clinical care service contracts have been reviewed and approved by both the medical staff and governing board within the past 12 months? □ Yes □ No Is there a current CLIA (Clinical Laboratory Improvement Act) certificate or waiver on file for all tests and laboratory services performed? C-0274 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3)(ii) Patient care policies must include policy and procedure for providing emergency services, addressing all of the requirements at 42 CFR 485.618 (tags C 200-209) Self-Evaluation: Comments/Actions □ Yes □ No Are there policies and procedures demonstrating how the CAH would meet all of its emergency service requirements (see tags C-200-209)? 16 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there evidence that all emergency care service policies/procedures have been reviewed and revised as needed by the required policy development group within the past 12 months? □ Yes □ No Can you demonstrate how the CAH provides 24 hour emergency care to patients? □ Yes □ No Do you have a list of what equipment, supplies, medications, blood and blood products are maintained onsite AND which are readily available for treating emergency cases by agreement at other facilities? If yes, where?__________________________________________________ □ Yes □ No Can you indicate what types of personnel are available to provide emergency services and what are their required onsite response times? □ Yes □ No Do policies address how the CAH coordinates with local EMS? C-0275 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3)(iii) Guidelines for the medical management of health problems that include the conditions requiring medical consultation and/or referral, the maintenance of health care records, and procedures for the periodic review and evaluation of the services furnished by the CAH. Self-Evaluation: Comments/Actions □ Yes □ No Do the written policies address circumstances under which consultation with other CAH professional healthcare staff or referral outside the CAH should occur? □ Yes □ No Do the written policies address maintenance of medical records in a manner consistent with 485.638? 17 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Do the written policies address periodic evaluation of the CAHs healthcare services in a manner consistent with the requirements of 485.641? C-0276 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3) (iv) Rules for the storage, handling, dispensation and administration of drugs and biologicals. There has been a lot of detail, information, and resources added to this tag within the state operations manual. Please review the SOM for details on the requirements. The CAH’s written patient care policies must include rules governing pharmacy services within the CAH. The CAH’s rules may be in the form of pharmacy services policies and procedures. These CAH rules must address storage, handling, dispensing, and administration of drugs and biologicals within the CAH. The rules must be in accordance with accepted professional principles of pharmacy and medication administration practices. Accepted professional principles include compliance with applicable Federal and State law and adherence to standards or guidelines for pharmaceutical services and medication administration issued by nationally recognized professional organizations, including, but not limited to: U.S. Pharmacopeia (http://www.usp.org) the American Society of Health-System Pharmacists (http://www.ashp.org/), the Institute for Safe Medication Practices (http://www.ismp.org/default.asp), the National Coordinating Council for Medication Error Reporting and Prevention (www.nccmerp.org); the Institute for Healthcare Improvement (http://www.ihi.org/ihi); or the Infusion Nurses Society (http://www.ins1.org). These rules must provide that... Responsibility for pharmacy services Storage of drugs and biologicals, including the location of storage areas, medication carts, and dispensing machines Proper environmental conditions Security Handling drugs and biologicals Compounding Use of outside compounders (Outsourcing Facilities) Use of Compounding Pharmacies Dispensing drugs and biologicals Administration of drugs and biologicals to patients Record keeping for the receipt and disposition of all scheduled drugs Ensuring that outdated, mislabeled, or otherwise unusable drugs are not used for patient care 18 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Assessing Adverse Drug Reactions & Medication Administration Errors Self-Evaluation: Comments/Actions □ Yes □ No Can you demonstrate that the CAH adopted pharmacy rules developed with the advice of the CAHs professional healthcare staff. □ Yes □ No Can you demonstrate the CAH identified the qualifications of the individual designated to be responsible for developing and implementing rules for the CAHs pharmacy services in accordance with state and federal law and the CAHs written policies? □ Yes □ No Does the CAH have procedures in place to ensure effective dispensing of medications from the pharmacy in a timely manner? They surveyor will review medical records for late administration of prescribed medications and will investigate if these delays are due to pharmacy dispensing delays. This may be a good topic to perform a QI project on! □ Yes □ No Does the CAH use a nationally recognized source of accepted professional principles of pharmacy practice in developing policies and procedures? Source: __________________________________________________________ □ Yes □ No Are drugs and biologicals stored in a secure manner? □ Yes □ No Are drugs stored in areas not accessible to unauthorized personnel? □ Yes □ No When drugs or biologicals are kept in a patient care area during hours when patient care is not provided, are they locked up? □ Yes □ No Can you demonstrate that drug inventory procedures are effective and result in an accurate inventory and all drugs are accounted for? □ Yes □ No Does the CAH have a system that tracks movement of scheduled drugs from point of entry into the CAH to point of departure (through administration to the patient, destruction of drug, or return to manufacturer)? 19 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Does the system provide documentation on scheduled drugs in a readily retrievable manner to facilitate reconciliation of receipt and disposition of all scheduled drugs? □ Yes □ No Can you demonstrate that the CAH is able to and has made efforts to reconcile and address any discrepancies. □ Yes □ No Can the CAH demonstrate that only a pharmacist or authorized personnel (in accordance with State and Federal law) compound, label and dispense drugs or biologicals regardless of whether the services are provided by CAH staff or under agreement? □ Yes □ No Do the CAH’s pharmacy rules address Automated Dispensing Cabinets (ADCs) if used with in the CAH? □ Yes □ No Can the CAH demonstrate that ADCs are being used in a manner prescribed by the CAHs rules? □ Yes □ No Can the CAH demonstrate that compounded medications used and/or dispensed by the hospital are being compounded consistent with standard operating procedures and quality assurance practices equivalent to or more stringent than the standards described in US Pharmacopeial Convention (USP) <795> and <797>? □ Yes □ No Can the CAH demonstration that the individual responsible for the pharmacy service, including compounding policies, practices and quality assurance within the CAH, and selecting and overseeing any external sources of compounded medications, has the expertise to conduct effective quality oversight consistent with USP <795> and <797> (or equivalent/more stringent) standards? □ Yes □ No Are compounded sterile preparations (CSPs) produced in the CAH? □ Yes □ No Can the individual responsible for the pharmacy services explain the risk level(s) of the CSPs being produced in-house and/or obtained from external sources? Can he or she demonstrate that the assigned risk levels are consistent with USP <797> or equivalent/more stringent standards? 20 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there evidence that the beyond use dating (BUDs) are determined consistent with the CAH’s rules, policies and procedures? □ Yes □ No Do the CAH policy and procedures demonstrate that CSPs are packaged in a manner to protect package integrity and sterility? Requirements with respect to motion, light exposure, temperature and potentially hazardous contents Should be addressed? □ Yes □ No Can the CAH demonstrate a process for ensuring that such information is effectively conveyed to non-pharmacy health care personnel and/or to patients/caregivers, if applicable? □ Yes □ No Can the CAH demonstrate that the policies and procedures are consistent with or more stringent than the applicable USP standards? □ Yes □ No Can it demonstrate that the pharmacy personnel assigned to determining BUDs when a manufacturer’s instructions are not available have the expertise and technical support needed to properly conduct the assessments needed to make such determinations in a manner consistent with standards and hospital policies? □ Yes □ No If the CAH obtains compounded products from an external source that is not an FDA registered outsourcing facility, can it demonstrate that it systematically evaluates and monitors whether these sources adhere to accepted professional principles for safe compounding? □ Yes □ No Does the CAH have a process for following up on adverse drug reactions (ADRs) and errors in medication administration reported by CAH staff in accordance with §485.635(a)(3)(v)? □ Yes □ No Can the CAH demonstrate that any ADRs were assessed, analyzed and corrective action taken by the CAH □ Yes □ No Does each patient’s individual drug container bears his/her full name and strength and quantity of the drug dispensed, as well as include appropriate accessory and cautionary statements, expiration date, and, when applicable, a BUD. 21 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Does each floor stock container bears the name and strength of the drug, lot and control number of equivalent, expiration date, and, when applicable, a BUD. C-0277 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3) (v) Policies include procedures for reporting adverse drug reactions and errors in the administration of drugs. There has been a lot of detail, information, resources, Quality Improvement suggestions added to this tag within the state operations manual. Please review the SOM for details on the requirements. Self-Evaluation: Comments/Actions □ Yes □ No Are there written procedures for reporting adverse drug reactions and errors? □ Yes □ No Is there evidence that these procedures are effectively implemented? □ Yes □ No Can the CAH demonstrate that ADRs and medication administration errors are reported to practitioners in a timely manner? □ Yes □ No Can the CAH demonstrate medications administered and/or drug reactions are promptly recorded in the patient’s medical record? □ Yes □ No What training and education has been provided to nurses on the concepts of medications errors that do and do not reach the patient and ADRs? □ Yes □ No Can CAH nursing staff demonstrate their knowledge of the concepts and the procedures for when a medication error or ADR occurs? 22 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Can the CAH provide evidence of training staff on reporting expectations? □ Yes □ No Does the CAH have a system for reporting/identifying ADRs and medication administration errors for QA/QI purposes? □ Yes □ No Is the individual responsible for the QA program able to demonstrate how the CAH determines if the number of medication administration errors and ADRs reported is consistent with the size and scope of services provided by the CAH? C-0278 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3) (vi) Policies include a system for identifying, reporting, investigating and controlling infections and communicable diseases of patients and personnel. There has been a lot of detail, information and resources added to this tag within the state operations manual. Please review the SOM for details on the requirements. Self-Evaluation: Comments/Actions □ Yes □ No Are there written procedures for identifying the infections and communicable diseases of patients and personnel? □ Yes □ No Are there written procedures for reporting the infections and communicable diseases of patients and personnel? □ Yes □ No Are there written procedures for investigating the infections and communicable diseases of patients and personnel? □ Yes □ No Are there written procedures for controlling the infections and communicable diseases of patients and personnel? 23 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there a designated qualified individual to be responsible for the infection control program? □ Yes □ No Can the responsible individual demonstrate that the CAHs program adheres to nationally recognized practices or guidelines? Practice/Guidelines used:______________________________ □ Yes □ No Is there evidence of the CAH training staff in infection control practices pertinent to their role? □ Yes □ No Can the responsible individual demonstrate how staff compliance with infection control program requirements is assessed and what corrective actions are taken? □ Yes □ No Can the responsible individual demonstrate that infection control incidents, problems, and trends are analyzed and that corrective actions are taken and further assessed? *********** Staff will be monitored to determine if: □ Yes □ No Staff employs safe infection control practices for preparing and administering medications. □ Yes □ No Staff employ standard precautions appropriately □ Yes □ No Staff employ safe infection control practices for preparing and administering medications? □ Yes □ No Staff perform active surveillance to identify infections C-0279 §485.635 (a) Standard: Patient care policies (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (3) (vii) If inpatient services are provided, policies include procedures that ensure that the nutritional needs of inpatients are met in accordance with recognized dietary practices and the orders of the practitioner responsible for the care of the patients, and that the requirement of §483.25(i) of this chapter is met with respect to inpatients receiving post hospital SNF (Swing bed) care. There has been a lot of detail, information and resources added to this tag within the state operations manual. Please review the SOM for details on the requirements. 24 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Self-Evaluation: Comments/Actions □ No Inpatients - N/A Are there written procedures for ensuring the nutritional needs of inpatients are met: □ Yes □ No in accordance with recognized dietary practices? □ Yes □ No with the order of the practitioner responsible for the care of the patient? □ Yes □ No Can the CAH demonstrate that the individual responsible for dietary services is qualified based on education, experience, specialized training, and, if required by State law, is licensed, certified, or registered by the State? □ Yes □ No Can the responsible individual demonstrate how the CAH uses Dietary Reference Intakes (DRIs) in its menus to meet the nutritional needs of patients? □ Yes □ No Do the medical record reflect that patients are assessed using a screening mechanism for the risk of malnutrition and nutritional complications? What mechanism is used: ____________________________________ □ Yes □ No Does the medical record reflect dietary orders in line with the assessment? □ Yes □ No Can the CAH demonstrate that dietary intake and nutritional status is being monitored, as appropriate? □ Yes □ No Is there documentation of swing bed patients maintaining acceptable parameters of nutritional status, such as body weight and protein levels, unless the resident's clinical condition demonstrates that this is not possible? □ Yes □ No Can the CAH demonstrate that all inpatient diets are prescribed by a practitioner(s) responsible for the care of the patient. □ Yes □ No If the State and the CAH permit dieticians or other nutrition professionals to order diets, has the CAH verified that they meet any requirements for licensure or certification under State law? 25 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** PATIENT SERVICES C -0281 §485.635 (b) Standard: Patient Services (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) (1) (ii) The CAH furnishes acute care inpatient services. In accordance with §485.620(b), CAHs are required to have an average annual per acute inpatient length of stay that does not exceed 96 hours. Accordingly, CAHs are expected to provide less complex inpatient services in order to comply with the length of stay requirement. Furthermore, for each Medicare beneficiary, the CAH is required in accordance with Medicare payment law and regulations to have the practitioner who admits the beneficiary as an inpatient certify that the beneficiary may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the CAH. However, while it may be true that CAHs generally are not expected to handle patients requiring complex, specialized inpatient services, such as those services provided by trauma centers, or cardiac surgery centers, CAHs should be able to handle a range of patient needs requiring inpatient admission. CMS does not believe it is in the best interest of patients for them to routinely be transferred to a more distant hospital if instead their care can be provided locally without compromising quality or the length of stay requirements (78 FR 50749). Accordingly, acute inpatient services must be furnished to patients who present to the CAH for treatment so long as the CAH has an available inpatient bed and the treatment required to appropriately care for the patient is within the scope of services offered by the CAH. There has been a lot of detail, information and resources added to this tag within the state operations manual. Please review the SOM for details on the requirements. Self-Evaluation: Comments/Actions There are no specific steps for this tag, however below are items that the surveyor will investigate. These may be helpful in improvement activities for appropriate transfers. ** Verify that the CAH is furnishing acute care inpatient services by reviewing data on the number of patients admitted over the prior year. ** Determine the percentage of ED visits that result in an admission to the CAH. If fewer than eight percent of ED visits lead to an inpatient admission, review data on transfers of ED patients, overall staffing, the volume and type of outpatient services offered, including observation services, and swing bed services to determine whether there is a reasonably proportionate relationship among the various services the CAH provides. 26 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** ** Review a sample of records of the patients the CAH transferred and determine if the transfers were appropriate based on the services available at the CAH. C-0282 §485.635 (b)(2) Laboratory Services (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) The CAH provides basic laboratory services essential to the immediate diagnosis and treatment of the patient that meet the standards imposed under section 353 of the Public Health Service Act (42 U.S.C. 236a). (See the laboratory requirements specified in part 493 of this chapter.) Laboratory services that must be provided on-site at the CAH’s main campus are the tests specified in the regulation, which would be considered the minimum necessary for diagnosis and treatment of a patient: (i) Chemical examination of urine by stick or tablet method or both (including urine ketones); (ii) Hemoglobin or hematocrit, (iii) Blood glucose; (iv) Examination of stool specimens for occult blood, (v) Pregnancy tests; and (vi) Primary culturing for transmittal to a certified laboratory. These services may be provided by the by the CAH staff or under arrangement or agreement, or through a combination of CAH staff and a laboratory under arrangement. Laboratory services, whether provided directly by the CAH or under an arrangement with a laboratory contractor, must have a current Clinical Laboratory Improvement Act (CLIA) certificate or waiver for all tests performed and meet the laboratory requirements specified in Part 493 of this chapter. The laboratory must have written policies and procedures for the collection, preservation, transportation, receipt, and reporting of tissue specimen results. Patient laboratory results and all other laboratory clinical patient records are considered patient medical records and the CAH must comply with the requirements of the clinical records CoP at §485.638(a)(4)(ii). Self-Evaluation: Comments/Actions □ Yes □ No Is there documentation of all laboratory services offered by the facility and location. □ Yes □ No Is there a CLIA certificate or waiver, as applicable, for all laboratory tests performed in the facility? □ Yes □ No If specimens are referred to another laboratory for testing, does the facility have documentation that the referral laboratory is CLIA certified for the appropriate tests? 27 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Are laboratory services that are necessary to support the emergency services of the CAH identified? C-0283 §485.635 (b)(3) Radiology Services (Rev. 138, Issued: 04-07-15, Effective: 04-07-15) Radiology services furnished by the CAH are provided by personnel qualified under State law, and do not expose CAH patients or personnel to radiation hazards. There must be written policies that are developed and approved by the governing body or responsible individual and are consistent with State law, that designate which personnel are qualified to use the radiological equipment and administer procedures. Radiological services furnished by the CAH may be provided by CAH staff or under arrangement. The CAH must maintain and have available diagnostic radiological services to support the services the CAH provides to meet the needs of its patients. These services must be available at all times the CAH provides services, including emergency services. The CAH has the flexibility to choose the types and complexity of radiologic services offered. They may offer only a minimal set of services or a more complex range of services (including nuclear medicine). All radiological services provided by the CAH, including diagnostic, therapeutic, and nuclear medicine, must be provided in accordance with acceptable standards of practice and must meet professionally approved standards for safety. Self-Evaluation: Comments/Actions □ Yes □ No Are there written policies that designate which personnel are qualified to use the radiological equipment, administer procedures, and which studies require interpretation by a radiologist. □ Yes □ No Are these policies developed and approved by the governing body or responsible individual? □ Yes □ No Is there evidence that these policies and procedures are implemented? 28 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Are there written policies and procedures that ensure safety from radiation hazards for patients and personnel? They must address at least the following: □ Yes □ No Adequate radiation shielding for patients, personnel and facilities, which includes: □ Yes □ No (i) Shielding built into the CAH’s physical plant, as appropriate; □ Yes □ No (ii) Types of personal protective shielding to be used, under what circumstances, for patients, including high risk patients as identified in radiologic services policies and procedures, and CAH personnel; □ Yes □ No (iii) Types of containers to be used for various radioactive materials, if applicable, when stored, in transport, in use, and when disposed; □ Yes □ No (iv) Clear signage identifying hazardous radiation areas; □ Yes □ No Labeling of all radioactive materials, including waste, with clear identification of all material(s); □ Yes □ No Transportation of radioactive materials between locations within the CAH; □ Yes □ No Security of radioactive materials, including determining who may have access to radioactive materials and controlling access to radioactive materials; □ Yes □ No Periodic testing of equipment for radiation hazards; □ Yes □ No Periodic checking of staff regularly exposed to radiation for the level of radiation exposure, via exposure meters or badge tests; □ Yes □ No Storage of radio nuclides and radio pharmaceuticals as well as radioactive waste; and □ Yes □ No Disposal of radio nuclides, unused radio pharmaceuticals, and radioactive waste. 29 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Are there written policies and procedures to ensure that periodic inspections of radiology equipment are conducted and problems identified are corrected in a timely manner? □ Yes □ No Is there a system in place to correct identified problems? □ Yes □ No Is there evidence of inspections and corrective actions? □ Yes □ No Is there documentation that periodic tests of radiology personnel by exposure meters or test badges are performed? C-0285 §485.635 (c) Standard: Services Provided Through Agreements or Arrangements All agreements for providing health care services to the CAH’s patients must be with a provider or supplier that participates in the Medicare program, except in the case of an agreement with a distant-site telemedicine entity for the provision of telemedicine services. Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that the facility has verified that every entity is under an agreement with Medicare (except distant-site telemedicine entities under agreement or arrangement). 30 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** PATIENT VISITATION RIGHTS C-1000 §485.635 (f) Standard: Patient Visitation Rights A CAH must have written policies and procedures regarding the visitation rights of patients, including those setting forth any clinically necessary or reasonable restriction or limitation that the CAH may need to place on such rights and the reasons for the clinical restriction or limitation. Self-Evaluation: Comments/Actions □ Yes □ No Are there written policies or procedures regarding the visitation rights of patients? Do policies address: □ Yes □ No Inpatient and outpatient; □ Yes □ No Clear rationale that restrictions are clinically necessary □ Yes □ No Reasons for restrictions/limitations □ Yes □ No How CAH staff that will enforce visitation be trained C-1001 §485.638(a) Standard: Patient Visitation Rights CAHs are required to inform each patient (or the patient’s support person, where appropriate) of his/her visitation rights. Self-Evaluation: Comments/Actions □ Yes □ No Is there a written notice of visitation rights made available for the patient? Does this notice address the following rights: □ Yes □ No Consent to receive visitors he or she has designated □ Yes □ No Receive the visitors he or she has designated □ Yes □ No Withdraw or deny his/her consent to receive specific visitors, either orally or in writing. 31 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there evidence that provision of the required notice is documented in the patient’s medical record? C-1002 §485.635 (f) Standard: Patient Visitation Rights The CAH’s visitation policies and procedures may not use the race, color, national origin, religion, sex, gender identity, sexual orientation, or disability of either the patient (or the patient’s support person, where appropriate) or the patient’s visitors (including individuals seeking to visit the patient) as a basis for limiting, restricting, or otherwise denying visitation privileges. Self-Evaluation: Comments/Actions □ Yes □ No Is there documentation in the visitation policies and procedures that the CAH DOES NOT restrict, limit or deny visitation to individuals on a prohibited basis? SURGICAL SERVICES C-0320 §485.639 Condition of Participation: Surgical Services (Rev. 84, Issued: 06-07-13, Effective: 06-07-13, Implementation: 06-07-13) If a CAH provides surgical services, surgical procedures must be performed in a safe manner by qualified practitioners who have been granted clinical privileges by the governing body, or responsible individual, of the CAH in accordance with the designation requirements under paragraph (a) of this section. Self-Evaluation: Comments/Actions □ Yes □ No Are there written policies governing surgical care? □ Yes □ No Do policies contain definition of the scope of surgical services and are approved by the governing body or responsible individual? 32 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Do these policies contain: □ Yes □ No Aseptic surveillance and practice, including scrub techniques □ Yes □ No Identification of infected and non-infected cases □ Yes □ No Housekeeping requirements/procedures □ Yes □ No Patient care requirements o Preoperative work-up o Patient consents and releases o Clinical procedures o Safety practices o Patient identification procedures □ Yes □ No Duties of scrub and circulating nurse □ Yes □ No Safety practices □ Yes □ No The requirement to conduct surgical counts in accordance with accepted standards of practice □ Yes □ No Scheduling of patients for surgery □ Yes □ No Personnel policies unique to the OR □ Yes □ No Resuscitative techniques □ Yes □ No DNR status □ Yes □ No Care of surgical specimens □ Yes □ No Malignant hyperthermia □ Yes □ No Appropriate protocols for all surgical procedures performed. These may be procedure-specific or general in nature and will include a list of equipment, materials, and supplies necessary to properly carry out job assignments. □ Yes □ No Sterilization and disinfection procedures □ Yes □ No Acceptable operating room attire □ Yes □ No Handling infections and biomedical/medical waste □ Yes □ No Does your facility have an informed consent form? Does the consent form contain the following requirements? □ Yes □ No Name of patient, and when appropriate, patient’s legal guardian; □ Yes □ No Name of CAH; □ Yes □ No Name of procedure(s); □ Yes □ No Name of practitioner(s) performing the procedure(s) or important aspects of the procedure(s), as well as the 33 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No □ Yes □ No □ Yes □ No □ Yes □ No □ Yes □ No name(s) and specific significant surgical tasks that will be conducted by practitioners other than the primary surgeon/practitioner. (Significant surgical tasks include: opening and closing, harvesting grafts, dissecting tissue, removing tissue, implanting devices, altering tissues.); Signature of patient or legal guardian; Date and time consent is obtained; Statement that procedure was explained to patient or guardian; Signature of professional person witnessing the consent; and Name/signature of person who explained the procedure to the patient or guardian. STATE EXEMPTION C-0326 §485.639 (e) Standard: State Exemption A CAH may be exempted from the requirement for MD/DO supervision of CRNAs as described in paragraph (c)(2) of this section, if the State in which the CAH is located submits a letter to CMS signed by the Governor, following consultation with the State’s Boards of Medicine and Nursing, requesting exemption from MD/DO supervision for CRNAs. The letter from the Governor must attest that he or she has consulted with the State Boards of Medicine and Nursing about issues related to access to and the quality of anesthesia services in the State and has concluded that it is in the best interests of the State’s citizens to opt-out of the current MD/DO supervision requirement, and that the opt-out is consistent with State law. The request for exemption and recognition of State laws and the withdrawal of the request may be submitted at any time, and are effective upon submission. 34 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** PERIODIC EVALUATION & QUALITY ASSURANCE REVIEW C-0330 §485.641 Condition of Participation: Period Evaluation and Quality Assurance Review While conducting the survey, a surveyor may identify a patient care practice or other CAH practice with which the surveyor is unfamiliar. Health care and CAH practice are continually changing due to new laws, regulations and standards of practice. C-0331 §485.641 (a) Standard: Periodic Evaluation (1) The CAH carries out or arranges for a periodic evaluation of its total program. The evaluation is done at least once a year and includes review of --Self-Evaluation: Comments/Actions □ Yes □ No Are there written procedures for conducting an evaluation of the facility’s total CAH program? □ Yes □ No Is there evidence that the evaluation has been conducted within the past 365 days? C-0332 §485.641 (a) Standard: Periodic Evaluation (1)(i) The utilization of CAH services, including at least the number of patients served and the volume of services; Self-Evaluation: Comments/Actions Is there evidence that the most current evaluation included: □ Yes □ No the number of patients served □ Yes □ No the volume of services 35 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0333 §485.641 (a) Standard: Periodic Evaluation (1)(ii) A representative sample of both active and closed clinical records; Notes: Montana requires 100% review of open and closed PA records, and a representative sample of FNP records. ED patients are considered “outpatient” Self-Evaluation: Comments/Actions Is there evidence that the most current evaluation included: □ Yes □ No review of at least 10% of inpatient clinical records, active and closed □ Yes □ No review of at least 10% of outpatient clinical records, active and closed Have you included in your count those records reviewed for... □ Yes □ No participation in clinical improvement studies □ Yes □ No participation in CMS performance reporting □ Yes □ No physician performance evaluation □ Yes □ No midlevel providers by a supervising physician □ Yes □ No other facility QI/PI projects □ Yes □ No medical records completeness, timeliness □ Yes □ No by medical staff for utilization review, mortality review, etc. C-0334 §485.641 (a) Standard: Periodic Evaluation Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that the most current evaluation included the CAH’s health care policies? □ Yes □ No Have all of the CAHs health care policies been reviewed and revised as needed within the past 12 months? 36 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0335 §485.641 (a) Standard: Periodic Evaluation (2) The purpose of the evaluation is to determine whether the utilization of services was appropriate, the established policies were followed, and any changes needed. Self-Evaluation: Comments/Actions □ Yes □ No Does the annual evaluation report contain a summary of the evaluation findings? Do the findings include: □ Yes □ No a statement, supported by hard data, that indicates whether or not the utilization of the CAH’s services in the past 12 months was appropriate, and if not, what action will be taken to correct this. □ Yes □ No a statement, supported by hard data, that indicates whether or not established policies were followed, and if not, what action will be taken to correct this. □ Yes □ No a statement, supported by hard data, of any changes that are needed □ Yes □ No a statement related to each proposed change indicating how the impact of proposed changes will be monitored and evaluated during the next 12 month period. C-0336 §485.641 (b) Standard: Quality Assurance The CAH has an effective quality assurance program to evaluate the quality and appropriateness of the diagnosis and treatment furnished in the CAH and of the treatment outcomes. The program requires that... 37 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that, over the past 12 months, the QA/PI program has evaluated the quality of diagnosis and treatment? □ Yes □ No Is there evidence that, over the past 12 months, the QA/PI program has evaluated the appropriateness of diagnosis and treatment? □ Yes □ No Is there evidence that the QA/PI program has evaluated treatment outcomes throughout the past 12 months? □ Yes □ No Is there evidence from the past 12 months that the CAH’s Quality Assurance/PI program is effective, ie, over the past 12 months.... Is there evidence that the program included: □ Yes □ No ongoing monitoring and data collection; □ Yes □ No problem prevention, identification and data analysis; □ Yes □ No identification of corrective actions; □ Yes □ No implementation of corrective actions; □ Yes □ No evaluation of corrective actions; □ Yes □ No measures to improve quality on a continuous basis. C-0337 §485.641 (b) Standard: Quality Assurance (1) All patient care services and other services affecting patient health and safety, are evaluated; Note: The minutes of the QA/PI committee should demonstrate that, over the course of 12 months, all departments/services in the facility have provided a quality report to the committee within the time frames outlined by policy. Also, be sure to integrate the findings and work of organization committees, including the Safety, Infection Control, P & T, Risk Management, Patient Safety, and others working on patient health and safety issues. 38 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that, over the past 12 months, the QA/PI program has evaluated all departments and services within the facility? Is there evidence that the dept/service included in its report information about: □ Yes □ No its ongoing monitoring and data collection? □ Yes □ No problem prevention, identification, and data analysis with the dept/service? □ Yes □ No identification of corrective actions? □ Yes □ No implementation of corrective actions? □ Yes □ No evaluation of corrective actions? □ Yes □ No measures to improve quality on a continuous basis? C-0338 §485.641 (b) Standard: Quality Assurance (2) Nosocomial infections and medication therapy are evaluated; Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that nosocomial infections are evaluated as part of the QA/PI Program? Is there evidence that the infection control program included in its report information about: □ Yes □ No its ongoing monitoring and data collection? □ Yes □ No problem prevention, identification, and data analysis with the dept/service? □ Yes □ No identification of corrective actions? □ Yes □ No implementation of corrective actions? □ Yes □ No evaluation of corrective actions? □ Yes □ No measures to improve quality on a continuous basis? 39 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there evidence that medication therapy is evaluated as part of the QA/PI Program Is there evidence that the medication therapy program included in its report information about: □ Yes □ No its ongoing monitoring and data collection? □ Yes □ No problem prevention, identification, and data analysis with the dept/service? □ Yes □ No identification of corrective actions? □ Yes □ No implementation of corrective actions? □ Yes □ No evaluation of corrective actions? □ Yes □ No measures to improve quality on a continuous basis? C-0339 §485.641 (b) Standard: Quality Assurance (3) The quality and appropriateness of the diagnosis and treatment furnished by nurse practitioners, clinical nurse specialists, and physician assistants at the CAH are evaluated by a member of the CAH staff who is a doctor of medicine or osteopathy or by another doctor of medicine or osteopathy under contract with the CAH; Self-Evaluation: Comments/Actions □ Do Not Use Mid-Levels, go to Tag C-340 □ Yes □ No Do the medical staff Bylaws, Rules and/or Regulations require physician review of the care provided by mid-levels (inpatients and outpatients)? □ Yes □ No Is the level of review required by the Bylaws consistent with the requirements of the SOM (see C-0260, % records reviewed)? □ Yes □ No Is there evidence that the designated physician supervisor has reviewed the care of each mid-level provider providing care? 40 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** □ Yes □ No Is there evidence that the physician and mid-level provider have participated together in the periodic review of patient health records (see C-0264) for QI purposes? □ Yes □ No Is there evidence that the physician-midlevel joint review has produced opportunities to improve diagnosis and/or treatment in the past 12 mo? □ Yes □ No Is there evidence that the physician-midlevel joint review has produced process or systems improvements in response to identified opportunities? □ Yes □ No Is there evidence that the process and/or system opportunities identified and improvements made were communicated to other facility medical providers, the QA/PI program and Board during the past 12 months? □ Yes □ No Is there evidence that the process and/or system opportunities identified and improvements made were communicated to the governing board during the past 12 months? C-0340 §485.641 (b) Standard: Quality Assurance (4) The quality and appropriateness of the diagnosis and treatment furnished by doctors of medicine or osteopathy at the CAH are evaluated by – (i) One hospital that is a member of the network, when applicable; (ii) One QIO or equivalent entity; or (iii)One other appropriate and qualified entity identified in the State rural health care plan... (iv)In the case of distant-site physicians and practitioners providing telemedicine services to the CAH’s patients under a written agreement between the CAH and a distant-site hospital, the distant-site hospital; or (v) In the case of distant-site physicians and practitioners providing telemedicine services to the CAH’s patients under a written agreement between the CAH and a distant-site telemedicine entity, one of the entities listed in paragraphs (b)(4)(i) through (iii)of this section; 41 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Self-Evaluation: Comments/Actions □ Yes □ No Does the medical staff Bylaws, Rules and/or Regulations require physician review of the diagnosis and treatment rendered by all physicians treated by the facility (inpatients and outpatients)? □ Yes □ No If the facility has more than one practicing physician on staff, do the Bylaws require both internal and external review of the diagnosis and treatment rendered? □ Yes □ No Is there evidence that the diagnosis and treatment provided by each staff physician is evaluated? □ Yes □ No Is there evidence that the diagnosis and treatment provided by each consulting physician is evaluated? □ Yes □ No Is there evidence that the reviews encompass the full range of cases the physician typically sees and treats in the facility in a year’s time? □ Yes □ No Is there evidence that the physician reviews have produced opportunities to improve diagnosis and/or treatment in the past 12 months? □ Yes □ No Is there evidence that the physician reviews have produced process or systems improvements in response to identified opportunities in the past 12 months? □ Yes □ No Is there evidence that the process and/or system opportunities and improvements identified through physician reviews were communicated to other facility medical providers and the QA/PI program during the past 12 months? □ Yes □ No Is there evidence that the process and/or system opportunities and improvements identified through physician reviews were communicated to the governing board during the past 12 months? 42 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Identify those sources through which you obtain internal physician review of diagnosis and treatment: □ other in-house physicians □ infection control committee □ P & T committee □ Patient Safety committee □ Risk Management committee □ Quality Committee or projects □ other __________________ □ Yes □ No Does your program for the review of the quality and appropriateness of diagnosis and treatment meet the requirements of this standard? C-0341 §485.641 (b) Standard: Quality Assurance (5)(i) The CAH staff considers the findings of the evaluations, including any findings or recommendations of the QIO, and takes corrective action if necessary. Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that the CAH staff have considered the findings of QA/PI evaluations and recommendations, including those obtained from the QIO? □ Yes □ No Have opportunities for improvement been identified in any of these evaluations/recommendations? □ Yes □ No Has corrective action/improvement been implemented in response to identified recommendations or opportunities for improvement? . 43 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0342 §485.641 (b) Standard: Quality Assurance (5)(ii) The CAH also takes appropriate remedial action to address deficiencies found through the quality assurance program. Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that the CAH staff have integrated the findings from regulatory survey deficiencies, QIO complaint investigations, HIPAA complaints, patient complaints, litigation and other sources with other improvement opportunities identified through the QA/PI program? □ Yes □ No Have opportunities for remedial action to correct deficiencies been identified from any source? □ Yes □ No Have corrective action/improvement been implemented in response to identified deficiencies? □ Yes □ No Is there evidence that corrective actions for identified deficiencies, from any source, have been evaluated for effectiveness using objective measures of performance? □ Yes □ No Is there evidence of ongoing intervention to achieve correction of identified deficiencies when initial steps do not achieve the necessary correction or desired result? 44 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** C-0343 §485.641 (b) Standard: Quality Assurance (5)(iii) The CAH documents the outcome of all remedial actions. Self-Evaluation: Comments/Actions □ Yes □ No Is there objective evidence and analysis that demonstrates corrective actions for identified deficiencies have corrected the problem, and that correction has been maintained for at least one year? □ Yes □ No Is there evidence that the correction of deficiencies has been communicated to the governing board? ORGAN, TISSUE, EYE PROCUREMENT C-0345 §485.643(a) Condition of Participation: Organ, Tissue & Eye Procurement §485.643(a) Incorporate an agreement with an OPO designated under part 486 of this chapter, under which it must notify, in a timely manner, the OPO or a third party designated by the OPO of individuals whose death is imminent or who have died in the CAH. The OPO determines medical suitability for organ donation and, in the absence of alternative arrangements by the CAH, the OPO determines medical suitability for tissue and eye donation, using the definition of potential tissue and eye donor and the notification protocol developed in consultation with the tissue and eye banks identified by the CAH for this purpose; Self-Evaluation: Comments/Actions □ Yes □ No Is there a written agreement with an Organ Procurement Organization? Who?_______________________________________________________________ 45 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** Does the OPO agreement contain, at a minimum, the following: □ Yes □ No The criteria for referral, including the referral of all individuals whose death is imminent or who have died in the CAH; □ Yes □ No Includes a definition of “imminent death”; □ Yes □ No Includes a definition of “timely notification”; □ Yes □ No Addresses the OPO’s responsibility to determine medical suitability for organ donation; □ Yes □ No Specifies how the tissue and/or eye bank will be notified about potential donors using S notification protocols developed by the OPO in consultation with the CAHdesignated tissue and eye bank(s); □ Yes □ No Provides for notification of each individual death in a timely manner to the OPO (or designated third party) in accordance with the terms of the agreement; □ Yes □ No Ensures that the designated requestor training program offered by the OPO has been developed in cooperation with the tissue bank and eye bank designated by the CAH; □ Yes □ No Permits the OPO, tissue bank, and eye bank access to the CAH’S death record information according to a designated schedule, e.g., monthly or quarterly; □ Yes □ No Includes that the CAH is not required to perform credentialing reviews for, or grant privileges to, members of organ recovery teams as long as the OPO sends only “qualified, trained individuals” to perform organ recovery; □ Yes □ No The interventions the CAH will utilize to maintain potential organ donor patients so that the patient organs remain viable. 46 (Updated December 2016, Rev. 163, 10-14-2016) CAH Quality Assurance Survey Readiness Self-Assessment **For tags supported by the Performance Improvement Network** SWING-BEDS C-0350 §485.645 Special Requirements for CAH Providers of Long-Term Care Services (SwingBeds) A CAH must meet the following requirements in order to be granted an approval from CMS to provide post-CAH SNF care, as specified in §409.30 of this chapter, and to be paid for SNF-level services, in accordance with paragraph (c) of this section. Self-Evaluation: Comments/Actions □ Yes □ No Is there evidence that the CAH is substantially in compliance with §409.30? 47 (Updated December 2016, Rev. 163, 10-14-2016)