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CMS Revises Immediate Jeopardy Policies

The Centers for Medicare & Medicaid Services has revised Appendix Q to the State Operations Manual, which includes guidance for identifying immediate jeopardy in health care settings.

To cite immediate jeopardy, surveyors must determine that noncompliance with one or more health and safety requirements caused or created a likelihood that serious injury, harm, impairment, or death to one or more recipients of care would occur, and immediate action is necessary to prevent the occurrence or recurrence of harm.

Appendix Q includes several key changes to the immediate jeopardy definition, including:

  • requiring, in situations where recipients have not already suffered harm, that the nature of the identified noncompliance must create a likelihood, or reasonable expectation, that such harm would occur if not corrected, not simply the potential for harm;
  • removing culpability as a required component to cite immediate jeopardy;
  • instructing surveyors to use a “reasonable person” concept to consider whether noncompliance has caused or made likely serious mental or psychosocial harm to care recipients; and
  • clarifying that no immediate jeopardy citations are automatic and that each citation must be decided independently.

The revised appendix also includes a template to assist surveyors in documenting each component of immediate jeopardy. Online basic training for Appendix Q is available on the Integrated Surveyor Training Website and aims to help identify immediate jeopardy. The training is intended for regional office and State Survey Agency surveyors, management staff, and training coordinators, as well as providers and other stakeholders.

For questions, email OSOG_GeneralInquiries@cms.hhs.gov with the subject line “Immediate Jeopardy Inquiry.”

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About the Author

Emily Schweich is a communications associate for America's Essential Hospitals.

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