Systems Improvement Agreement
The Centers for Medicare and Medicaid Services (CMS) has a new quality improvement tool to gain compliance from hospitals with repeat or multiple Immediate Jeopardy (IJ) findings on compliance or validation surveys: the Systems Improvement Agreement (SIA).
The SIA allows hospitals to continue receiving CMS funding while a third-party monitors its policies, facilities, and patient care until the serious problems that caused them to fall out of compliance are fixed. The agreement grants the hospital additional time to make sustainable improvements in complex quality, cultural, policy, and procedural deficiencies.
The alternative to an SIA—Medicare Decertification—is to cut off CMS funding completely in as few as 23 days if the problem is not corrected. For most hospitals, Medicare Decertification can close the hospital, as CMS funding may account for 40-70% of their revenue.
Termination can have serious detrimental effects on hospitals and the communities they serve. In the interest of ensuring the availability of health care services, such a heavy weapon is used reluctantly.
The SIA approach represents an intermediate step between full revocation of participation in Medicare/Medicaid and ongoing repeated surveys and corrective action responses. As such, it gives CMS a mechanism for prompting large-scale organizational change in the face of noncompliance without the drastic move of revocation.
Efforts to develop, track, and analyze provider SIA progress nationally indicate CMS’s intent to increasingly employ this hospital compliance tool. As a result, CMS may be using the SIA to ensure long-term problem resolution, not just quick fixes.
For more information on Systems Improvement Agreements and how Compass Clinical Consulting is prepared to help your organization respond to this new tool, send us an email or contact our office at (513) 241.0142.