CMS has reissued the S & C Memo due to the replacement Memo listed had the S & C numbers transposed. The correct S & C Memo that this one replaces is S & C Memo 15-16-NH. No other changes were made. Thank you.

CMS is revising the CMP analytic tool in the following areas:

* Past noncompliance will have a per-instance CMP imposed if something occured before the current survey and has been fully addressed and back in compliance

* Per Instance CMP is the Default for Noncompliance that existed before the Survey

* Per Day CMP is the Default for Noncompliance Existing during the Survey and Beyond – however Per Day will used for noncomplaince that occured with serious harm at IJ level, abuse or persistent deficient pratices

* Revisit Timing for the revisit survey to certify compliance when imposing the final CMP amount

* Review of High CMPs of $250,000 or greater by CMS Central Office

 

The S & C memo and the CMP analytical tool for users sent from CMS are linked here