Articles and Blogs

Noncompliance cited as immediate jeopardy (“IJ”) is one of the most severe survey findings for certified Medicare and Medicaid provider entities. According to the Centers for Medicare & Medicaid Services (“CMS”), IJ “represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious... READ MORE

The Consolidated Appropriations Act, 2021 (the “Act”) was signed into law on December 27, 2020 and recasts the Medicare hospice survey requirements and establishes new Medicare enforcement options and procedures. The Act’s hospice provisions generally track those contained in the Helping our Senior Population in Comfort Environments, also known as the HOSPICE Act, which... READ MORE

On March 5, 2019, the Center for Clinical Standards and Quality/Survey & Certification Group released a memorandum titled “Revisions to Appendix Q, Guidance on Immediate Jeopardy” (“Memorandum”). The Memorandum’s revisions create a “Core Appendix Q” that will be used by surveyors of all provider and supplier types in determining when to cite immediate jeopardy.... READ MORE