The Revised Appendix Q

On March 5, 2019, CMS sent a memo to the State Survey Agencies regarding revisions in Appendix Q, Guidance on Immediate Jeopardy.  Here is a summary of the key changes: Likelihood instead of potential:  This changes the previous version in that it clarifies that rather than a “potential for serious harm,” in order to cite IJ in situations where residents or patients have not suffered serious injury, harm, impairment or death, the surveyor is to determine whether the noncompliance creates a “likelihood” (reasonable expectation) that such harm will occur if not corrected. (this is consistent with what the C.F.R. already defined as Immediate Jeopardy with the language “likely to cause.”  42 C.F.R. 488.301 Culpability has been removed:  It is no longer a required component to cite IJ. Psychosocial harm–Surveyors are to determine whether noncompliance has caused or made likely serious mental  or psychosocial harm…

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