Staying current with regulatory and stroke certification changes can be daunting for stroke coordinators and other stroke program leaders. Often changes are communicated to others in the organization such as those in the finance or regulatory departments. Without knowing the full impact of changes – or even discerning those related to the stroke program through a myriad of changes – updates to the stroke team may be delayed for weeks, months or even until an adverse impact to the program surface (financial losses, citations during intra-cycle or recertification reviews, etc.)
The purpose of this blog is to summarize the timing of routinely scheduled regulatory changes and provide useful resources that can be used to monitor for release of changes.
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Certification Standards
In the case of disease-specific certifications like stroke, agencies such as The Joint Commission, DNV-GL and HFAP, communicate directly with the hospital accreditation contact in the regulatory or compliance department. These individuals have access to the accreditation agency’s “extranet site” or “customer portal” where they receive periodic updates from the agency. Sometimes stroke coordinators have access to the extranet site or customer portal and can look for updates and other resources there. Talk to your hospital accreditation contact about access. Also, The Joint Commission, for instance, has a monthly publication called, Joint Commission Perspectives to formally notify hospitals of changes in conditions of participation, eligibility requirements and standards of compliance. DNV-GL sends stroke program Advisory Notices with updates. HFAP has a Blog on its website that may be helpful. Stroke program leaders will need to make sure that these periodic updates are forwarded to them. If e-Alerts/Advisories are offered that provide updates on certification, sign up for them. They are sent to your email daily/weekly/monthly and can help alert you to upcoming changes.
Scheduled updates are generally released once a year and most often give programs six months advance notice to implement the changes. For instance, The Joint Commission releases annual changes in June/July with effective dates at the beginning of the next year. There is also a public comment period that precedes the notice of updates. And we encourage all programs to review the proposed changes and comment. You can obviously only do that if you get the information timely.
The Joint Commission, DNV-GL and HFAP all released new certification manuals for 2019, adding their version of advanced Primary Stroke Centers performing thrombectomies. These are usually available free to already certified programs – through your hospital’s accreditation contact.
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CMS (Medicare) Rules
CMS has a regular schedule for annual updates outlining payments for hospital stays, emergency room visits and outpatient services for both hospitals and physicians.
Hospital scheduled updates are released for public comment in or around June/July with final regulations publicly announced in late August. Changes take effect at the beginning of Medicare’s fiscal year which is October 1.
Physician fees are updated a little later with changes effective at the beginning of the calendar year, January 1.
You may recall changes that came from CMS in the past such as stroke drip-and-ship payments, the 2-midnight rule, rehabilitation therapy payment caps, hospital 30-day readmission penalties and meaningful EHR use payments. The CMS changes are more complicated to follow. We suggest finding someone in the finance department that monitors these changes and asking them to help you stay abreast of what might impact your stroke program as they dissect the Medicare annual updates – for 2019, all 2,593 pages of it! Knowing the schedule of updates will help you know when to reach out to them.
In summary, to stay current on regulatory changes:
- Sign up for e-Alerts/Advisories/Blogs, if available, from stroke program certification agencies
- The Joint Commission: https://www.jointcommission.org/ealerts/
- DNV-GL: https://www.dnvgl.us/assurance/healthcare/index.html
- HFAP (blog available on the website): https://hfap.org/blog/
- Sign up for list-servs through your professional organizations or regional stroke coordinator groups (AANN, ASA, etc.)
- Connect with someone in your regulatory department and coordinate getting certification agency stroke program updates to you
- Connect with someone in your finance department and coordinate getting any CMS changes that impact the stroke program to you
Lastly subscribe to our blog, Twitter and Facebook! We will use our social media and blog to bring you useful information on managing your program and stroke care in general. Through our eBooks, consultative sessions and weekly postings, we hope to create a community of stroke leaders who help each other stay current!
