Effective April 2, 2012: CMS Region VI delegated State Survey Agencies the authority to provide notice to SNF and SNF/NF facilities that CMS will impose Optional Denial of Payment for New Admissions (ODPNA) in a “No Opportunity to Correct Before Remedies are Imposed” Enforcement Action.

Opportunity to Correct Survey: Facility is allowed an opportunity to correct identified deficiencies before remedies are imposed. Includes Deficiencies written at Scope and Severity of A, B,C, D, E, F, G (not double G)

No Opportunity to Correct Survey The facility will have remedies imposed immediately after determination of noncompliance has been made.

1. Immediate Jeopardy (IJ) not lifted prior to exit - two (2) day notice of ODPNA 2. Immediate Jeopardy (IJ) lifted prior to exit – 15 day notice of ODPNA 3. Double “G” – 15 day notice of ODPNA No Opportunity to Correct Situations Include:

Purpose of Delegating Notice of ODPNA: “To encourage the facility to achieve prompt compliance and to sustain compliance with the Medicare/Medicaid Requirements of Participation.”

Change in Process for Providers: Effective date for ODPNA is now from date of initial letter sent from Health Standards Section, not from CMS letter.

ODPNA Enforcement Letter Contains New / Revised Paragraphs: - Optional Denial of Payment for New Admissions (ODPNA) - Appeal Rights paragraph revised