CMS Releases FY2024 Mission & Priorities Document

NAHC Report

The Fiscal Year (FY) 2024 Mission and Priorities Document (MPD) developed by the Centers for Medicare & Medicaid Services’ (CMS) Quality, Safety & Oversight Group (QSOG) and Survey & Operations Group (SOG) was recently posted. The mission is to assure basic levels of quality and safety for all patients, residents and clients receiving care from Medicare and Medicaid certified institutional providers. 

The MPD is an annual document that directs the work of QSOG, SOG, and State Survey Agencies (SAs) based on regulatory changes, adjustments in budget allocations, new initiatives, and new requirements based on statute. The MPD covers survey, certification, enforcement, and the Medicare funding allocation process for states. Survey activities must be scheduled and conducted per the priority tier structure provided in the MPD. The four priority tiers reflect statutory mandates and program emphases, with tier 1 being the highest priority and tier 4 being the lower priority.

The MPD structure includes three sections: (1) new program updates since the issuance of the previous FY MPD; (2) standing information that is not anticipated to change throughout the year; and (3) listing of the priority tier structure for survey & certification activities by provider and supplier type.

A notable change from last year’s MPD is that CMS is moving up the priority for initial surveys for both home health and hospice.

  • Tier 1 – Providers/suppliers with a CMS-determined access to care issue.
  • Tier 2 – Provider/Supplier’s application to Medicare exceeds 150 days with a deeming option- If more than 150 days has passed since the MAC has recommended approval of the application and a deeming option exists, then the initial certification would be a Tier 2 priority.

In the past, initial certification surveys were classified as Tier 4. Also, in the MPD, challenges with State Agency (SA) surveyor staffing and a backlog of surveys is reiterated.  These challenges result in an emphasis being placed on complaints related to patient care with harm to patients taking the highest priority.

NAHC is aware that CMS is working on updates to the State Operations Manual (SOM), Chapter 10, that deals with the alternative sanctions for home health.  CMS intends to update this chapter and incorporate the enforcement remedies for hospice.  The sanctions/remedies include:

  • Civil money penalties;
  • Suspension of payment for all new admissions;
  • Temporary management
  • Directed plan of correction; and
  • Directed in-service training

The MPD mentions that CMS is working on these updates but a timeframe for when to expect these to be released is not shared.

NAHC is also aware that CMS has been working on updating the home health survey process which is found in Appendix B of the SOM.  Based on discussions with CMS, we believe this will include updates of the interpretive guidelines to incorporate clarifications of interpretations.  Unfortunately, a specific timeframe for this has not been shared and it is not mentioned in the MPD.