WHAT YOU NEED TO KNOW ABOUT THE IDR & IIDR PROCESS. Phyllis Carson, Adm. Brett Coble, Adm./Owner Tamara Meadows, RN-BC

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1 WHAT YOU NEED TO KNOW ABOUT THE IDR & IIDR PROCESS Phyllis Carson, Adm. Brett Coble, Adm./Owner Tamara Meadows, RN-BC

2 IDR- Informal Dispute Resolution SNF/NFs and ICF/MRs have one opportunity to dispute deficiencies Informal, no attorney s allowed Must be requested and all materials submitted within same time frame as POC- 10 calendar days of receiving 2567 If not timely, facility waives right to IDR Results not final until reviewed by CMS

3 IIDR- Independent IDR Required by Affordable Care Act 2010 Started 2012 at OSDH Only Offered by CMS after CMP s are Imposed- Monies are Escrowed Panel consists of 3-5 members who are rotated, does not include OSDH employee Documents generated by IIDR not disclosable to public/attorney s Results not final until reviewed by CMS

4 What Can or Cannot be Disputed? Deficiencies- 1 or more All or part of examples: Especially if S/S is H, removing 1-2 examples could reduce to G Scope & Severity ONLY if Substandard Examples not Appropriate for cited F-tag Cannot dispute Survey Process Cannot dispute Fairness / Inconsistencies Cannot dispute Remedies

5 IDR- Informal Dispute Resolution Only submitted materials can be used at IDR, no additional materials allowed Additional ORIGINAL materials can be brought in form of a notebook, organized and tabbed for easier reference during IDR IDR material is ed to IDR Panel for pre-review, IDR Coordinator would appreciate at least a single copy not in booklet format for ing

6 Who is the IDR Panel? HB 1729 in 2008 approved IDR Panel All are conducted by the IDR Panel Panel consists of 5 members: 2 Volunteers experienced in LTC operations 1 OSDH employee with surveyor exp. 1 Representative of Disability/Aging Community 1 Additional non-osdh employee All panel members are volunteers & were provided required training Members are rotated Conflicts of interest are avoided per disclosure

7 Types of IDR All types are reviewed by the Panel: Face-to-Face In Person with surveyor team present More Common Record Review Records are submitted for review only Rare Telephone Conference Panel members & survey team meet at OSDH w/ facility representatives via phone Difficult for lengthy disputes

8 HOW TO REQUEST AN IDR Complete an OSDH IDR Request form Include all evidence of dispute Redact info r/t privacy: Names- Resident/Family DOB, SS#, Rm#, Adm. Date, Phone# Personal Identifying Info Submit to IDR Coordinator at OSDH Turn in POC under separate cover to IDR Coordinator

9 What to Submit???? IDR prep begins during the survey Make copies of materials given to survey team for later reference If appropriate, take a picture, date stamped preferably Keep it simple Don t overdue the materials submitted Highlight the one sentence on the page if needed Gather statements from staff, resident, family members, physician

10 What to Submit???? Know the meaning and interpretative guidelines of the cited F-Tag Is the F-Tag appropriate for examples Read 2567 word for word- is it accurate? Investigate! Review old medical records, lab reports, medical reports, etc. Interview staff Interview physician Review with appropriate consultants for their input

11 Example of Successful IDR Summary: We do not believe that all the fall interventions utilized were recognized as evidenced by the 2567 fails to mention such things as a physical restraint which was finally utilized after all other alternatives were tried. Not all interventions are written on the actual incident report, but are found in the chart in other places as seen in the following attachments. Therefore, we do not believe the facility lacked supervision or interventions as noted. See Resident #1 Fall Intervention Timeline.

13 Results of IDR Panel may do one of the following: Delete deficiency Delete or alter part of deficiency Change S/S if substandard Make No Changes Facility is notified of findings in writing 7-10 days If altered, resubmit with new POC otherwise old unaltered 2567 will be released to public

14 State IDR Statistics Fiscal Year 2012: 27 IDR s 6 IIDR s 74 Tags Disputed 11 Tags Modified 5 Tags Deleted

15 Nice to Know s Re-Survey timeline continues despite IDR IDR may be scheduled after Re-Survey and after deficiencies cleared The Survey Team is required to be represented at the IDR, so no re-survey will be done during the IDR However, it can occur within minutes/hours after the IDR Two-hour Maximum Time Frame for IDR Hearing

16 Nice to Know s Survey Team will typically let their 2567 stand as their evidence without presenting any oral argument Then facility has the right to introduce their evidence and their witnesses The Panel will have questions of Surveyors & Facility Witnesses No recordings are kept Not the time to Complain about the Team s attitude etc. They will still be your Team!

17 GOOD LUCK!

Effective Date April 17, New Policy. Amends. Replaces: WPD GO 430 VLEPSC: ADM.25.07, ADM.25.09, OPR.07.04, OPR

Effective Date April 17, New Policy. Amends. Replaces: WPD GO 430 VLEPSC: ADM.25.07, ADM.25.09, OPR.07.04, OPR WINCHESTER POLICE DEPARTMENT OPERATION ORDER NOTE: This policy is for internal use only, and does not enlarge an employee s civil liability in any way. It should not be construed as the creation of a higher