Lessons Learned: The Hard Way

November 9, 2011
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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.

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.