Core Appendix Q and Subparts - Appendix Q to the State Operations Manual (SOM), which provides guidance for identifying immediate jeopardy, has been revised. The revision creates a Core Appendix Q that will be used by surveyors for all provider and supplier types to determine when to cite immediate jeopardy.
Revision summary:
· All guidance for laboratories that was previously in Appendix Q will be moved to the new Subpart XI: Clinical Laboratory Improvement Amendments of 1988 (CLIA).
· The Centers for Medicare and Medicaid Services (CMS) has drafted subparts to Appendix Q that focus on immediate jeopardy concerns occurring in nursing homes and clinical laboratories since those provider types have specific policies related to immediate jeopardy. Appendix Q has been revised to reinsert language referring criminal acts to local law enforcement.
· Subpart XI has been revised to reflect that laboratories can cease testing to remove the immediacy of the Immediate Jeopardy. Laboratories must determine and correct the root cause of the deficiency, issue corrected reports as applicable, and establish a mechanism to monitor the effectiveness of the actions before determination of compliance.
· Key Components of Immediate Jeopardy – To cite immediate jeopardy, surveyors determine that (1) noncompliance, (2) caused or created a likelihood that serious injury, harm, impairment, or death to one or more recipients would occur or recur, and (3) immediate action is necessary to prevent the occurrence or recurrence of serious injury, harm, impairment, or death to one or more recipients.
· Immediate Jeopardy Template – A template has been developed to assist surveyors in documenting the information necessary to establish each of the key components of immediate jeopardy. Survey teams must use the immediate jeopardy template attached to Appendix Q to document evidence of each component of immediate jeopardy and use the template to convey information to the surveyed entity.
