CMS Systems Improvement Agreement (SIA)

An 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.

Compass Clinical Consulting has a 100% success rate in removing Immediate Jeopardy findings and achieving successful Systems Improvement Agreement (SIA) resolution.

Although there are many reasons for an organization to embrace an SIA, perhaps the most significant rationale is the opportunity to take a “breather” from continuous scrutiny and compliance visits. An SIA includes an organization-wide assessment, gap analysis, corrective plan, and implementation, only resulting in a new official survey afterward. There is the time, space, and external support to address concerns, design better systems, and develop staff to meet or exceed the CMS Conditions of Participation.

Compass Clinical Consulting was the external monitor and consultant for a State Hospital when that organization received and successfully resolved an SIA. This one-year process resulted in the hospital emerging as a different, vibrant organization. The CMS surveyors who conducted the follow-up survey even stated that;

“This isn’t the same hospital we left last year!”

Many hospitals hold similarities to this State hospital; tight resources, beleaguered staff, unprepared managers, and inadequate quality monitoring systems.

The good news is that the situation is fixable.

The Alternative to an SIA?

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.

An Intermediate Step

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.


Contact Us

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 (800) 241.0142.

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