CMS Streamlines Approval Processes for Outpatient Clinics

The survey and certification process for approval of outpatient physical therapy clinics is now simpler, thanks to a survey and certifications memorandum from the Centers for Medicare & Medicaid Services. The provisions of the memorandum also make it easier for clinics' extension locations to meet state agency survey standards.

The CMS Center for Clinical Standards and Quality released the memorandum in August, clarifying the requirements for primary site and extension location surveys, surveys of extension locations, and their conditions of participation, or CoPs.

Streamlined Forms Better Align With State Operations Manual

Rehabilitation agencies are permitted to apply to CMS for approval of another location near their primary site to provide additional access to care. These "extension locations" share administration, supervision, and services with the primary site.

The agency's State Operations Manual historically has been inconsistent in its requirements for surveying primary and extension site locations that have applied for certification. To streamline Medicare enrollment and certification processes for outpatient clinics and to address the evolving expansion of outpatient rehab services provided across settings and locations, CMS has updated its forms to better align with the manual. In a memorandum to state survey agency directors, CMS provides additional guidance on survey and certification activities related to extension locations.

Guidance on Four Areas of Surveys and Certification

Form CMS-381, which clinics use to request certification in Medicare or Medicaid for initial and extension site locations, has been updated to include information from Form CMS-1856, which will be retired. Clinics now complete only CMS-381 for initial certification, administrative changes, changes of ownership, and during recertification surveys. In addition, CMS provided guidance to state survey agency directors in these four areas:

1. Outpatient clinics can now establish one or more extension sites at the same time they request a primary site via Form CMS-381, reducing the number of times they need to submit a form.
2. CMS removed outdated and conflicting language in the State Operations Manual that required accrediting organizations to survey all sites. It is now up to the discretion of the state agency and accrediting organizations whether they need to survey both primary sites and extension locations.
3. Extension locations no longer have to independently meet all of the CoPs as a rehab agency if they are located sufficiently close to the primary site to adequately share administration, supervision, and services.

CMS notes that in this situation, if an extension location is identified as noncompliant, the primary site would also be noncompliant since the extension site does not independently meet the conditions.

CMS still expects extension sites to meet the following CoPs:

485.711 Condition of Participation: Plan of Care and Physician Involvement.

485.713 Condition of Participation: Physical Therapy Services.

485.715 Condition of Participation: Speech Pathology Services.

485.721 Condition of Participation: Clinical Records.

485.723 Condition of Participation: Physical Environment.

485.725 Condition of Participation: Infection Control.

1. The memorandum reiterates that while extension locations usually must be within a 30-mile radius, they may be approved beyond that distance. The clinic's request must meet the approval criteria and must include adequate documentation to support the clinic's ability to maintain oversight. See the memorandum for a list of the extension location approval criteria.

Stay on the lookout: These changes are effective immediately, and CMS is working on revisions to Chapter 2 of Appendix E in the State Operations Manual that will incorporate these and other updates. Until those edits are made, states are to follow the Transitioning Certification Functions for Changes of Ownership, Administrative Changes, and Initial Enrollment Performed by the SOG Locations memo.