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Understanding Optional Denial of Payment for New Admissions: CMS Guidance Effective April 2012

On April 2, 2012, CMS Region VI delegated authority to state survey agencies regarding the Optional Denial of Payment for New Admissions (ODPNA). This enforcement action allows facilities an opportunity to correct deficiencies identified during surveys before remedies are imposed, but certain situations, like Immediate Jeopardy (IJ), will result in immediate remedies without correction time. The process for providers has changed; the effective date for ODPNA now starts from the initial letter from the Health Standards Section. For more details, contact Cindy Collins at 225-342-1997 or cindy.collins@la.gov.

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Understanding Optional Denial of Payment for New Admissions: CMS Guidance Effective April 2012

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  1. Optional Denial of Payment

  2. Effective April 2, 2012: CMS Region VI delegated State Survey Agencies the authority to provide notice to SNF and SNF/NF facilities that CMS will impose Optional Denial of Payment for New Admissions (ODPNA) in a “No Opportunity to Correct Before Remedies are Imposed” Enforcement Action.

  3. Opportunity to Correct Survey: Facility is allowed an opportunity to correct identified deficiencies before remedies are imposed. Includes Deficiencies written at Scope and Severity of A, B,C, D, E, F, G (not double G)

  4. No Opportunity to Correct Survey The facility will have remedies imposed immediately after determination of noncompliance has been made.

  5. No Opportunity to Correct Situations Include: 1. Immediate Jeopardy (IJ) not lifted prior to exit - two (2) day notice of ODPNA 2. Immediate Jeopardy (IJ) lifted prior to exit – 15 day notice of ODPNA 3. Double “G” – 15 day notice of ODPNA

  6. Purpose of Delegating Notice of ODPNA: “To encourage the facility to achieve prompt compliance and to sustain compliance with the Medicare/Medicaid Requirements of Participation.”

  7. Change in Process for Providers: Effective date for ODPNA is now from date of initial letter sent from Health Standards Section, not from CMS letter.

  8. ODPNA Enforcement Letter Contains New / Revised Paragraphs: - Optional Denial of Payment for New Admissions (ODPNA) - Appeal Rights paragraph revised

  9. Contact Information:Cindy Collins, RN, CCRNMedical Certification Program ManagerPhone: 225-342-1997E-Mail: cindy.collins@la.gov

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