Effective April 2, 2012:
CMS Region VI delegated State Survey
Agencies the authority to provide notice
to SNF and SNF/NF facilities that CMS
will impose Optional Denial of Payment
for New Admissions (ODPNA) in a “No
Opportunity to Correct Before Remedies
are Imposed” Enforcement Action.
Opportunity to Correct Survey:
Facility is allowed an opportunity to
correct identified deficiencies before
remedies are imposed.
Includes Deficiencies written at Scope
and Severity of A, B,C, D, E, F, G (not
double G)
No Opportunity to Correct
Survey
The facility will have remedies imposed
immediately after determination of
noncompliance has been made.
No Opportunity to Correct
Situations Include:
1. Immediate Jeopardy (IJ) not lifted prior
to exit - two (2) day notice of ODPNA
2. Immediate Jeopardy (IJ) lifted prior to
exit – 15 day notice of ODPNA
3. Double “G” – 15 day notice of ODPNA
Purpose of Delegating Notice of
ODPNA:
“To encourage the facility to
achieve prompt compliance and
to sustain compliance with the
Medicare/Medicaid
Requirements of Participation.”
Change in Process for Providers:
Effective date for ODPNA is now
from date of initial letter sent from
Health Standards Section, not
from CMS letter.
ODPNA Enforcement Letter
Contains New / Revised Paragraphs:
- Optional Denial of Payment for New
Admissions (ODPNA)
- Appeal Rights paragraph revised