Grievances and Complaints: Complying with the CMS CoPs, Joint Commission, DNV Standards and OCR

Product Id : HE236
Instructor : Sue Dill Calloway
Jul 13, 2020 1:00 PM ET | 12:00 PM CT | 10:00 AM PT | 120 Minutes

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If a CMS surveyor showed up at your hospital tomorrow would you know what to do? Are you sure you are in compliance with the entire grievance requirements by CMS, OCR, and the complaint standards by the Joint Commission or your accreditation organization? Do you have a grievance committee? Do you provide a written response as required by CMS? The CMS grievance requirements have recently been a frequent source of investigation. In fact, it was the third most common problematic standard for hospital. The grievance standards are located in the patient rights section.

This program will talk about a federal law that is enforced by the Office of Civil Rights requirements under Section 1557 of the Affordable Care Act. This law previously required many specific things and was revised on June 19, 2020. The hospital must still have a grievance procedure and compliance coordinator to investigate any grievances alleging noncompliance with this law including discrimination.

Come learn what you need to ensure compliance. Many hospitals are surprised at the number of regulations and the detailed requirements on what they need to do to comply with this problematic standard. This program will also discuss the Joint Commission standards on complaints and DNV Healthcare on grievances and how these cross walk to the CMS grievance interpretive guidelines. This is a must attend for any hospital. Staff should be aware and follow the hospital grievance and complaint policy. The policy should be approved by the board. Staff should be educated on the policy. This program will cover what is now required to be documented in the medical record.

Learning Objectives:

  • Discuss that any hospital that receives reimbursement for Medicare patients must follow the CMS Conditions of Participation on grievances. 
  • Identify that the CMS regulations under grievances includes the requirement to have a grievance committee,
  • Discuss that the Joint Commission has complaint standards in the patient’s right (RI) chapter and DNV grievance standard in the patient rights chapter
  • Recall that in most cases the patient must be provided with a written notice that includes steps taken to investigate the grievance, the results, and the date of completion.
  • Describe that the Office of Civil Rights requires hospitals to have a process to handle grievances related to discrimination under Section 1557 and that there were significant changes on June 19, 2020

Session Highlights:

  • Overview and background of CMS Conditions of Participation on grievances
  • CMS’ regulations that requires hospitals to have a grievance committee
  • Joint Commission’s complaint standards in the patient’s right (RI) chapter and DNV grievance standard in the patient rights chapter
  • Providing a written notice to patients
  • OCR’s requirement for hospitals to have a process to handle grievances related to discrimination under Section 1557
  • Final interpretive guidelines
  • How to find the current copy of the regulations
  • Going through the CMS deficiency memo
  • How to find changes in the Hospital CoPs
  • CMS definition of grievance
  • TJC definition and six elements of performance on complaints
  • Form to collect information
  • HIPAA requirements if request not from patient
  • Billing issues and information on patient satisfaction
  • Telephone complaints after discharge
  • Customer service and complaints
  • Process for prompt resolution
  • Board’s responsibility in grievance process
  • Changes to QIOs process
  • Time frame for responding to grievances
  • 7 day rule
  • System analysis approach
  • What should critical access hospitals do?
  • DNV Health NIAHO standards on grievances
  • OCR Section 1557 on complaint process
  • Policy required
  • Notice to patient
  • Grievance process
  • Appeal to CEO or board
  • Time lines for filing grievance on discrimination
  • Job description for compliance person

Who Will Benefit:

  • Consumer Advocates or Patient Advocate
  • Chief Operating Officer (COO)
  • All nurses in direct patient care
  • Joint commission coordinator
  • Department directors
  • Quality improvement coordinators
  • Risk managers
  • Legal counsel
  • Nurse educator
  • Patient safety officer
  • Emergency department manager
  • Compliance officers
  • HIPAA privacy and security officer
  • Anyone involved in the implementation of the CMS grievance, DNV, OCR, or Joint Commission complaint standards    
Speaker Profile:

Sue Dill Calloway, RN, MSN, JD, is the president of Patient Safety and Healthcare Consulting and Education company with a focus on medical-legal education especially Joint Commission and the CMS hospital CoPs regulatory compliance. She also lectures on legal, risk management and patient safety issues. She was a director for risk management and patient safety for five years for the Doctors Company. She was the past VP of legal services at a community hospital in addition to being the privacy officer and the compliance officer. She was a medical malpractice defense attorney for ten years. She has 3 nursing degrees in addition to a law degree.

She is a well-known lecturer and the first one in the country to be a certified professional in CMS. She also teaches the course for the CMS certification program. She has written 102 books and thousands of articles.

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