I get a fair number of visitors to my blog who are students of healthcare professions or early careerists working they way up through leadership structures. And, given my background, many come from health administration programs. Since most of my posts are focused on effective hospital leadership and I truly believe in the importance of dealing with "The Good, The Bad and The Ugly", I am presenting an update on a case study from my own neighborhood.
Earlier this year Centers for Medicare and Medicaid Services (CMS) visited the County-operated locked psychiatric facilitiy in Santa Barbara and I shared my thoughts on the subject in a blog post The Value of Experienced Hospital Administrators. It has now come to light that CMS returned for a follow-up visit (as I would expect), which has resulted in a notice to initiatie proceedings to terminate the hospital's Medicare provider agreement on or before January 11, 2012.
This should be quite disturbing for the Santa Barbara County community. First, with the loss of Medicare funding, we can also expect Medicaid and private payor funding to cease. That means, the County will either need to continue operation of the facility without funding or find another facility to provide the services. In addition, the Psychiatric Health Facility (PHF) should also expect a visit from Licensing and Certification and possible action from the State. In other words, the microscope will be turned on and the heat turned up.
I've read the Statement of Deficiencies and Plan of Correction and just have to say that "time is of the essence" when responding to CMS or other statements of deficiencies. The notice states that termination of PHFs agreement with CMS may be avoided if, by October 27th, "credible documentation evidencing correction of the cited deficiencies that the hospital is otherwise in compliance with all Conditions of Participation applicable...". They also advise that "mere plans of future correction or evidence of progress toward correction will not be sufficient."
Unfortunately, the plan of correction proposes training, audits and other actions to be implemented in the future - specifically in and around November 10th -- exactly what CMS has said would be insufficient. So, what is CMS to do without losing the confidence of the public. Yes, that's right --terminate their agreement with the PHF. (Ugggghhhhhh!) It makes me ill just thinking about this!
The lessons in summary:
- Expect to see CMS when you accept their reimbursement
- Expect them to return (unannounced) to see that you have corrected the deficiencies they found and that there are no other deficiencies.
- Take the Statement of Deficiencies seriously and make the needed corrections immediately... not plan to do so a month later.
Regulatory information is available on the CMS site at Psychiatric Hospital Certification & Compliance. The special requirements for psychiatric hospitals in the Conditions of Particiation are detailed in:
Visit EdHat (a local social news blog) to see their reader comments on the article at http://www.edhat.com/site/tidbit.cfm?id=1215&tid=1394&art=73809&srt=asc
Posted by: Christina | November 11, 2011 at 11:53 AM
When it rains, it pours! Looks like one of my old hospitals also had a couple of visits from CMS http://www.vcstar.com/news/2011/nov/12/vcmc-gears-up-to-improve-care-after-critical/ I believe Dr. Gonzalez and his staff truly understand the seriousness of correcting the deficiencies - immediately.
I've been through a couple of CMS surveys and they felt like Joint Commission on steroids. However, we did well and only had a short list of things to improve.
Posted by: Christina | November 23, 2011 at 08:40 AM
The County's psychiatric health facility was deemed to be in compliance after another survey in December. This is good news for the community and those with mental illness. http://www.noozhawk.com/local_news/article/011212_santa_barbara_county_phf_back_in_compliance/
Posted by: Christina | January 22, 2012 at 12:55 PM