The Centers for Medicare and Medicaid Services (CMS) announced it is moving guidance and survey procedures for End-Stage Renal Disease facilities to Appendix H of the State Operations Manual (SOM).

According to Amy Miller, director of clinical and regulatory services for the American Health Care Association, this change aligns ESRD survey guidance with how guidance is organized for other provider types. 

The agency is also updating the guidance to include recent regulatory changes, previous QSO memos, and technical clarifications for ESRD facility requirements and expectations. This includes guidance and survey processes for home dialysis in nursing homes from QSO-18-24-ESRD, Miller said. 

She said the purpose of these updates is to make the information more current, organized, and easier to access. Here are the effects of the changes on nursing homes, Miller said:

1. More consistent ESRD survey scrutiny. ESRD surveyors are directed to conduct on-site nursing home visits when an ESRD facility provides home hemodialysis or peritoneal dialysis to residents under a written agreement. They will observe machine prep, initiation, vascular access care, discontinuation, environment, records, resident interviews, and staff competency.  

   
   

2. Written agreements matter. Surveyors will request that all nursing homes that ESRD facility has written agreements provide treatment locations, resident names, modality/schedule, nursing home personnel involved, and copies of agreements.  

   
   

3. Training/competency is key. The ESRD facility remains responsible for training and verifying the competency of nursing home staff who administer dialysis, with records checked in both the nursing home and ESRD facility files. 

   
   

4. Care coordination must be documented. Surveyors will look for coordination between the nursing home interdisciplinary team (IDT) and ESRD IDT on orders, care plans, complications, adverse events, transfers, psychosocial/nutritional needs, and prompt communication of dialysis issues. 

   
   

5. Infection control and environment are more visible. Surveyors will assess clean/dirty separation, hand hygiene, personal protective equipment, blood spills, waste, supply storage, catheter/access care, equipment disinfection, and treatment space in resident rooms or common areas. 

   
   

6. Equipment/water safety remains ESRD's responsibility. Appendix H stresses ESRD responsibility for equipment maintenance, repair, logs, chlorine testing, reverse osmosis/preconfigured systems, and backup dialysis planning. 

   
   

7. Not a new direct nursing home CoP/F-tag. The Appendix H changes are ESRD Conditions for Coverage, but nursing home survey referrals may occur if ESRD surveyors see non-dialysis or overlapping nursing home quality concerns.  

   
   

Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.