Renegade Accreditation Surveyors
◗ Re: "11 Dings That Might Surprise You" (August, page 32). Speaking as
a retired Medicare surveyor (now consultant), accreditation surveyors
must adhere to the standards to which they are surveying, not to their
own interpretation of these standards. If there is no regulatory (not the
Interpretive Guidelines) statement that refers to the issue, even indirectly,
then the surveyors are imposing their own "underground" regulation,
which cannot be enforced. A facility can only be cited under the CMS reg-
ulations for non-compliance with a regulation and/or nationally accepted
standards of care and services. Under a Medicare survey, you can (diplo-
matically) challenge a potential citation by asking the surveyors to identify
where, in the regulations or standards, the issue under review is in viola-
tion.
Bruce Ettinger,
MD, MPH
Santa Monica, Calif.
bbemdmph@aol.com
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