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AT LAST! CMS Says Providers Are Not Required to Put Plans of Correction on Forms Published on July 3, 2017

Elizabeth Hogue
Attorney in Private Practice
At last! On June 16, 2017, the Centers for Medicare and Medicaid Services (CMS) issued New Guidance for the Formatting of Plans of Correction that was effective immediately.

In a Memorandum Summary, CMS stated as follows:

“Format for Plans of Corrections (POCs)/Allegation of Compliance (AOC):
Providers/Suppliers and Clinical Laboratory Improvement Amendments (CLIA) Laboratories will no longer be required to write their PoC (for CLIA, this includes AOCs) on the right side of the CMS Form 2567. Providers/Suppliers or CLIA Laboratories may submit their PoC/AOC as a separate document attachment or may continue to document the PoC on the right side of the CMS Form 2567.
Signature on First Page: The Laboratory Director or Provider/Supplier Representative’s signature is still required on the first page of the CMS Form 2566 for the PoC/AOC. The PoC/AOC can be sent as an attachment to the signed first page of the CMS Form 2567.”
So, this means that providers and suppliers are no longer required to enter their PoCs in the far right hand column of the Statement of Deficiency. Instead, providers and suppliers are allowed to submit their PoC’s in any format so long as they include a signed first page of CMS Form 2567.
CMS also provided several reminders to providers and suppliers regarding PoCs as follows:
“An acceptable plan of correction must contain the following elements:
The plan of correcting the specific deficiency. The plan should address the processes that lead to the deficiency cited.
The procedure for implementing the acceptable plan of correction for the specific deficiency cited
The monitoring procedure to ensure that the plan of correction is effective and that specific deficiency cited remains corrected and/or in compliance with the regulatory requirements
The title of the person responsible for implementing the acceptable plan of correction.”
The content of PoC’s, therefore, remains the same, but there is now flexibility with regard to the format. Form 2567 doesn’t have to be used at all for the content of the PoC!

CMS also reminds providers and suppliers that PoC’s are publically releasable documents so providers and suppliers are required to omit any Privacy Act or Protected Health Information. If such information is included in PoC’s, surveyors will require amended PoC’s that do not include such information.
Flexibility in the format in which PoCs are submitted may seem like a small thing, but under the time pressures and other stresses associated with development and submission of PoCs, it’s “Yuuuge!”

©2017 Elizabeth E. Hogue, Esq. All rights reserved.

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