Since the Centers for Medicare & Medicaid Services enhanced enforcement for infection control citations, we have seen our Quality In-Cite® subscribers experiencing increased instances of providers getting caught in a discretionary denial of payment for new admissions (DDPNA) situation with DDPNA imposed sooner than the typical 90-day timeframe.
While providers know that civil money penalties (CMP) and directed plans of correction (DPOC) may be impositions as a result of an F880 citation (even low-level, isolated instances), many are not aware of the accelerated timelines associated with DDPNA that shorten the imposition timeline to 45 days, 30 days, or even 15 days instead of the standard 90 days.
The DDPNA effective date (45, 30 or 15 days) is dependent upon facility history of non-compliance and scope and severity of F880, coupled with the current non-compliance scope and severity of F880.
It is imperative administrators and directors of nursing thoroughly read and review the entire survey cover letter that accompanies the Statement of Deficiencies (SOD). The survey cover letter provides critical information the facility needs to understand and follow in order to achieve compliance. Facility leadership must identify and remain cognizant of the date the letter indicates DDPNA will go into effect.
If additional citations are received on another survey prior to desk review or revisit and official notification of substantial compliance for the F880 citation/survey, state survey agencies are considering the survey timeline to be open from the survey resulting in the F880 citation, regardless of the alleged date of compliance for F880. DDPNA is being imposed within the 45 days, 30 days, or 15 days.
Don’t fall into the F880 and DDPNA trap. If your facility receives additional citations on a survey after the F880 citation/survey, consider it one open non-compliance survey timeline. Ensure all citations are corrected and substantial compliance is achieved prior to the proposed DDPNA date associated with F880.
Contact your state survey agency and request a desk review or revisit occur promptly after the alleged compliance date.
Angi Livingston, MHA, BSN, RN, is a Senior Consultant at Formation Healthcare.
The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.