Survey Citations - Front-End CoP Tags

SOM Pub. 100-07, Appendix M · QSO-23-08 · 42 CFR 418.52 / 418.54 / 418.56 / 418.22 / 418.104

Hospice CoP Training

Educational Use Only

QSO-23-08 (January 6, 2023): CMS directed surveyors to use a quality-of-care investigative approach. Phase I CoPs - patient rights, initial/comprehensive assessment, IDG/POC - receive enhanced scrutiny. Condition-level citations trigger termination proceedings.

Patient Rights - 42 CFR 418.52

Tag	Requirement	Common Deficiency	Prevention Control
L522 (418.52(a))	Rights delivered verbally and in writing before care is provided during initial assessment	Rights delivered after clinical tasks began; no signed acknowledgement; English-only for non-English speaker	Sequence rights delivery as first documented step; track acknowledgements separately
L523 (418.52(a)(1))	Rights content meets all required elements and is understandable	Generic form used without modification; representative signature without documented authority	Verify communication needs at triage; confirm representative designation before first visit

Initial & Comprehensive Assessment - 42 CFR 418.54

Tag	Requirement	Common Deficiency	Prevention Control
L524 (418.54(a))	RN initial assessment within 48 hours of election	Non-RN conducted visit; visit after 48-hour window; visit documented as social visit only	RN-only initial assessments; real-time 48-hour deadline tracking
L530 (418.54(b))	IDG comprehensive assessment within 5 calendar days	Single-clinician assessment; day-count error (Day 0 vs Day 1 confusion)	Day 0 = election effective date; IDG coordinator owns completion checklist
L531–L537	All 7 assessment domains completed	Spiritual or bereavement marked N/A without clinical basis; drug profile skipped	Domain completion tracking; rationale required for any deferral

IDG & Plan of Care - 42 CFR 418.56

Tag	Requirement	Common Deficiency	Prevention Control
L543 (418.56(b))	POC before care; individualized	Generic templated POC; POC created after care delivery	POC generated from assessment data; patient-specific goals required
L544 (418.56(c))	POC review every 15 calendar days	'Reviewed - no changes' note without clinical support; reviews skipped during high census	14-day automated alert; reviews document specific clinical findings

Claim Denial Risk Triggers (Not Just Survey - Payment Consequences)

NOE filed/accepted after Day 5 without documented exception
Election statement missing required content or signatures
Certification missing patient-specific narrative
Oral certification exception not documented when written cert was late
F2F attestation missing signature date or encounter date (3rd+ periods)
F2F conducted by attending physician rather than hospice physician or NP
F2F encounter outside the 30-day window before benefit period
POC not in record before claim period begins

Educational Use Only. Not legal advice. Verify against SOM Appendix M and current primary sources.