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Potential Impact to Medicare/Medicaid Certification from The Joint Commission’s Updated Policy

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Potential Impact to Medicare/Medicaid Certification from The Joint Commission’s Updated Policy

A recent policy revision issued by The Joint Commission (“TJC”) may affect healthcare providers that undergo organization changes going forward, such as adding or deleting health services, programs, or site locations. In an Official Publication notice issued this week, the agency announced that, effective October 1, 2016, all organizations accredited with the TJC will now have to notify the agency in writing whenever a significant change is contemplated-or more specifically, whenever leadership within the organization has approved moving ahead with a proposed change and has identified a timeframe for implementing that change.

This revision may impact all TJC-accredited healthcare organizations that project growth and structural change in the future, and will require heightened preparation whenever such changes are anticipated. The update represents a shiftfrom the agency’s prior policy, which simply required organizations to notify the TJC within 30 days after a significant change had occurred (although the new policy still requires organizations to update its electronic application for accreditation within 30 days after the change has officially been implemented). The TJC advised its new protocol is necessary to provide the agency with sufficient advanced notice to evaluate how the change could potentially impact accreditation compliance, and whether it rises to the level of requiring renewed onsite survey activity. Given that many providers utilize the TJC’s Medicare deeming authority, failure to notify the agency could implicate Medicare/Medicaid certification and payment.

Please let us know if you have any questions regarding the TJC’s revised policy for notification of organizational changes. Murer is available to discuss the revised policy in more detail or explain its potential impact to providers in the future. We will continue to monitor the agency’s policies, and all the latest updates can be found at www.murer.com. Please contact our office for more information at (708) 478-7030.

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