1) Will the provider be afforded the opportunity for both an IDR and an IIDR? If both IDR and IIDR are afforded to the provider and there is conflict in the results, how will this be resolved)?
2) Will CMS provide additional funding to states to implement this?
3) How will the Resident, the Resident’s spokesman and/or the ombudsman be contacted regarding CMS imposed penalties? Will the provider be required to notify them (or post) when CMPs are imposed and the provider disputes the fine/penalty?
4) Is the provider being afforded in this new process, the opportunity to again question the findings in the deficiency or is the IIDR only being offered for the provider to dispute the process of imposing the penalty, such as “Is it a repeat degiciency?” or “Is the fine accurately reflected in the dollar amount of the fine (based on severity of the deficiency)?”
5) The 60 day timeline (from notification of imposition by CMS of the penalty) for the completion of the IIDR process may be too restrictive in that the facility has 30 days to request IIDR leaving little time for the process to be utilized (notification of all parties, receipt of documentation from affected persons and time for the IIDR team to review, report, and the state Agency to review and conclude the process). 60 days is not enough time. Will CMS consider the 60 day completion window to start from request of IIDR?
Dell Carolyn-LA
This is comment on Proposed Rule
Medicare and Medicaid Programs: Civil Money Penalties for Nursing Homes
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