When a surveyor cites "immediate jeopardy" at a provider, supplier or laboratory's location, it can lead to serious consequences, including potential fines and termination from federal healthcare programs. On March 5, 2019, CMS issued guidance for the first time in about 15 years, substantially revising guidelines that state inspectors should follow when citing immediate jeopardy. Immediate jeopardy citations are supposed to be reserved for situations where patients are likely to suffer or have suffered "serious injury, harm, impairment or death" as a result of noncompliance with federal health and safety requirements.
A finding of immediate jeopardy involves "the most severe and egregious threat to the health and safety of recipients." The key changes to Appendix Q of the State Operations Manual include the following:
The new guidance is effective immediately and all surveyors are expected to be trained on the new provisions by March 22, 2019.
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