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H&W Analysis of new Interpretive Guidelines
H&W Interpretive Guidance Change Summary Now Available

The H&W 2015 IG Change Summary was developed by H&W Independent Solutions as a detailed analysis of the changes made to the Interpretive Guidelines (IG) for Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IIDs). This new guidance is contained in Appendix J to the State Operations Manual (SOM), published April 27, 2015.

This change is the first update to the IG in several years. It is very comprehensive in that the guidance for almost all regulations has been modified to some extent, through either modification of the language, removal of language or addition of new language. Significantly, all the Compliance Principles, Probes and Facility Practice statements have been removed from Appendix J and a new Exhibit 355 attached to the SOM has been created.

The new CMS IG and Exhibit 355 contain nearly 200 pages of information. Less than 10% of the W-tags remained the same, with changes in either interpretive guidance, compliance principles, facility practice statements or probes. Save your organization a lot of time, resources and energy by acquiring this analysis from H&W for only $129.

It is important to note language that remains the same and has not changed, is not provided in this tool. This includes language that was in the previous SOM in the IGs and remained the same but was moved to the Exhibit.

Therefore, this document is not intended to be a substitution for Appendix J or the SOM. H&W advises the ICF/IID provider to obtain a copy of the new SOM and Exhibit from the Centers for Medicare and Medicaid (CMS) website or other authorized source. Copies can be obtained through a link at the www.hwisolutions.com website.

This tool specifically provides a guide to identify:

1) Language which was removed from the interpretive guidance;

2) Language which was added to the interpretive guidance; and

3) Language which has been modified in the interpretive guidance.

To buy your copy of this highly useful and extensive analysis (nearly 300 pages) for only $129, please visit the H&W Online Store: Click here to go to the H&W online store and this product listing.

For those of you who missed our Webinar Series about this change in the Interpretive Guidelines, please watch for an upcoming announcement about another presentation of the webinar in June.

If you received this notice from a colleague rather than directly from H&W, please email info@hwisolutions.com to add your name to our email announcement list.

Disclaimer: This document and the analysis herein is NOT associated with the Centers for Medicare and Medicaid Services (CMS) in any way. The opinions and advice offered are based on the experience and knowledge of the H&W staff. The content is based on the Appendix J and Exhibit 355 to the State Operations Manual (SOM), published April 27, 2015. You may want to seek additional guidance from your state survey agency or regional CMS office.

info@hwisolutions.com


May 3, 2015
CMS Releases Updated Survey Guidance for ICF/IID compliance The Centers for Medicaid and Medicare (CMS) have now released the updated ICF/IID Interpretative Guidelines (IG). This new guidance is effective as of April 27, 2015, so any new compliance surveys should be conducted using this information. The new guidance was first made available in January 2015 as an �Advance Copy�. A few changes have been made to this guidance, but it is substantially the same as the advance copy. There are two parts to the new IGs. The second part, �Exhibit 355, Probes and Procedures for Appendix J, Part II - Interpretive Guidelines - Responsibilities of Intermediate Care Facilities for Individuals with Intellectual Disabilities�, includes the Compliance Principles and the �probes� or questions that have been very useful in understanding what surveyors look for when making decisions about compliance. CMS has placed them in a separate �Exhibit� to accompany the Appendix J Guidance. H&W is developing a document that will illustrate the changes from the previous IGs and give guidance to providers on the new expectations, including additional policies and procedures that are outlined in the updated IGs. We are also planning a repeat of the webinar series that reviews the changes from the previous Appendix J guidelines. The written product will be released in May 2015 and the webinars will be conducted in late June. Watch for newsletters and announcements in the near future when these offerings become available. Please assure that we have your updated email information. For more information and to download a copy of the new Guidelines and Exhibit 355, see the article on the H&W Independent Solutions website by clicking here: �CMS Publishes New Survey guidelines for ICF/IID�.

April 28, 2015

NEW DOWNLOADABLE REFERENCE: COMBINED ICF/IID INTERPRETIVE GUIDANCE (8/15) AND EXHIBIT 355

In April 2015, CMS published the ICF/IID Appendix J – Interpretive Guidelines (IGs) to clarify the intent of the Conditions of Participation (CoPs) for ICF/IID and incorporate current standards of practice. This change was the first comprehensive update to the IG in nineteen years. Less than 10% of the interpretation for the regulatory W-tags remained the same. It is critical to update your resource materials to stay current for ICF/IID surveys.

As part of the change, the Compliance Principles, probes and procedures were removed from the IGs and placed into a separate Exhibit (Exhibit 355) behind the IGs. To fully interpret the regulations it is now necessary to refer to two separate sections of the regulations. CMS published a further update on August 14, 2015.

H&W incorporated the Exhibit 355 section with the IGs (including the most recent update) so that the guidance, probes and procedures for each regulation, are now found on a single page.

SAMPLE:

W194 (4) Staff must be able to demonstrate the skills and techniques necessary to implement the individual program plans for each client for whom they are responsible.

Interpretive Guidelines §483.430(e)(4)

Staff are observed in various settings during the day correctly and consistently implementing the specific IPPs of the clients with whom they are working. EXHIBIT 355: Observation and interview verify whether staff is competent and knowledgeable about the needs, programs, and progress of each sampled client with whom they are assigned to work.


This new resource is now available for purchase and download as a PDF document.

To buy your copy of this highly useful reference guide please visit the H&W Online Store: Click here to go to the H&W online store and this product listing.

This document is available as a single user purchase for $89.00 and in quantity discounts. A five (5) copy bundle is available at a 15% discount for $378. A ten (10) copy bundle is available at 25% off the single copy price for only $668.00.

This is a downloadable product in pdf format. It is an electronic product only. You will NOT receive a printed/hardcopy in the mail. A link to the product download will be included in the invoice you receive via email. Be sure to click on the link and save the file to your computer or server. For multiple copy bundles, you will be able to download the file multiple times. Be careful to change the file name each time or it will overwrite previously downloaded copies.

If you received this notice from a colleague rather than directly from H&W, please email info@hwisolutions.com to add your name to our email announcement list.

Disclaimer: This document and the analysis therein is NOT associated with the Centers for Medicare and Medicaid Services (CMS) in any way. The content is based on the Appendix J and Exhibit 355 to the State Operations Manual (SOM), published April 27, 2015 along with the August 14, 2015 update. For specific guidance, you may want to contact your state survey agency or regional CMS office.


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July 19, 2016

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