Very recently, the federal Centers for Medicare and Medicaid Services updated its guidance on the survey and enforcement process in key ways. These include, for example, how Immediate Jeopardy citations are handled, civil money penalties are or are not immediately imposed, and when treatment of a deficiency as "past noncompliance" is available.
Attorneys with substantial experience in effective responses to survey and enforcement actions will discuss this updated federal guidance and what it means for facilities, how to anticipate a survey when incidents occur, responses to IJ citations and high CMPs, and other tools and approaches.