Slide 1

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
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
“To encourage the facility to
achieve prompt compliance and
to sustain compliance with the
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