CMS Guidance on Survey Process for Reviewing Home Dialysis Services in a Long-Term Care (LTC) Facility

PUBLISHED: Sep 14, 2018
Relevant to: Dialysis Facilities, Long Term Care

The U.S. Centers for Medicare and Medicaid Services (CMS) recently released a memorandum describing the survey process for reviewing home dialysis services performed in a Long-Term Care (LTC) Facility. According to CMS, Medicare participating End Stage Renal Disease (ESRD) facilities must comply with the Conditions for Coverage at 42 CFR Part 494. Under this provision, Medicare-approved ESRD facilities may provide dialysis services to LTC residents in a LTC facility with an approved Home Training and Support modality.

ESRD facilities that provide home hemodialysis or peritoneal dialysis services to LTC residents must comply with 42 CFR Part 494, including the requirements set forth at §494.100: Care at home.

CMS requires surveyors evaluating home dialysis in the nursing home to conduct a minimum of two on-site visits to nursing homes where ESRD patients are receiving home dialysis services. Observations at these on-site visits will include:

  • Observations of machine setup
  • Vascular access care
  • Initiation and discontinuation of home hemodialysis treatments

Observations of actual peritoneal dialysis care is not required unless the survey team identifies concerns such as high rates of infection or complaints. If observations of peritoneal dialysis care are indicated, the surveyor should observe connection and disconnection from the cycler or manual CAPD exchange and evaluate the peritoneal dialysis exit site for signs of infection or improper care.

ESRD facilities can benefit from reviewing the CMS memorandum and understanding CMS surveyors are planning to observe during the survey process.

The CMS memorandum in attached.

Included with today’s notice are example policies related to the provision of dialysis services within the long-term care environment.

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