Update: Two Major Health Care Accrediting Organizations Will Resume Surveys in June 2020

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Accredited organizations should begin to prepare for the resumption of survey activity in a modified form. Organizations that are experiencing a COVID-19 surge or have other challenges may want to reach out to the accrediting organization to discuss the impact of survey activity at this time.
 

We described in a previously published Health Care Counsel Blog Post that, in response to the COVID-19 crisis, both The Joint Commission and DNV GL Healthcare had suspended regular surveying to allow health facilities to focus their resources on fighting the virus. The Joint Commission noted at the time that it would perform any postponed surveys once it resumed normal operations. Both organizations have now announced the upcoming resumption of survey activity, though each approach the process differently.

On May 27, 2020, The Joint Commission announced that it will resume regular surveys and reviews beginning in June 2020. According to the Joint Commission, account executives will contact health facilities to “assess the impact that the coronavirus pandemic had on their operations and their current state.” Importantly, the Joint Commission stated that it “will not retroactively review compliance.” Instead, reviewers will seek to “understand how you have adapted to the pandemic and review your current practices to assure you are providing safe care and working in a safe environment.”

According to The Joint Commission, it will prioritize surveys based on “low-risk areas in which we can go in safely to survey.” Joint Commission reviewers will also employ physical distancing practices to the extent possible; details about what this will entail are included in the announcement.

On May 13, 2020, DNV GL Healthcare announced that, effective June 1, 2020, it would begin conducting remote annual accreditation surveys for acute and critical access healthcare organizations, as well as any Condition Level Follow Up surveys resulting from the annual surveys. However, DNV GL is not yet restarting reaccreditation surveys for organizations with deemed status. DNV GL notes that due to the public health emergency, this will not affect Medicare participation and DNV GL will issue accreditation extensions if the hospital’s current accreditation expires. DNV GL reiterated that, despite the continued suspension of reaccreditation surveys, hospitals must still remain compliant with accreditation requirements and Medicare conditions of participation at all times.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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