Learn How CMS CoPs Help Fight Medical Errors

By Susan Dooley

When you see the term CoP, do you think of the nickname of your friendly neighborhood policeman? Or
does your mind immediately jump to the phrase Conditions of Participation? If you answered the latter,
you are a true healthcare business pro.
Periodically, CMS issues proposed rules that it publishes in the Federal Register. These proposed rules
revise the requirements, or conditions of participation, that hospitals must meet to participate in the
Medicare and Medicaid programs.

The Coding Institute LLC, 2222 Sedwick Road, Durham, NC 27713, Eenterprise Contact: Sam Nair, Direct: 704 303 8150,
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Decode CMSs 2016 Pharmacy and Medication Hospital CoPs

CMS recently issued a 45-page memo announcing changes to its hospital CoP standards for pharmacies
effective in 2016, including changes to regulations regarding medication compounding and beyond-use
dates. Additionally, CMS included language allowing surveyors inspecting hospitals to be able to cite
organizations for noncompliance.
The CMS memo on pharmaceutical services also regulates infection control, specifically with safe
injection practices as well as improving the use of antimicrobial drugs to avoid development of
multidrug-resistant organisms; medication timing changes that broaden administration time guidelines;
required policies and procedures; standardization of prescribing and communication practices; and
weight-based dosing calculation standards.
Dont work in a pharmacy? If your primary focus is on health information management, youll be glad to
know that CMS conditions of participation also cover regulations on medical records, their organization,
availability, and use. You can download CMSs State Operations Manual, including conditions of
participation for medical records, here.

Beat Medical Errors CMS Joins the Fight

With medication errors being the most common type of medical error, CMS is highly motivated to crack
down on its oversight of healthcare facility pharmacy services. The journal BMJ recently published a
study revealing that medical error in inpatient facilities is the third leading cause of death in the United
States, after heart disease and cancer. The study estimated that in 2013 alone, 251,454 people died
from a medical error.
The studys authors, Martin Makary, MD, MPH, professor of surgery, and research fellow Michael
Daniel, both from Johns Hopkins University School of Medicine in Baltimore, Maryland, noted that its
tough to capture statistics on medical error deaths. The problem is a dearth of accurate, transparent
information about medical errors, Makary said, and a medical coding-related deficit is the root of that
problem, because cause of death information on death certificates depends on ICD-10-CM codes for
statistics. While the ICD system offers great breadth and depth of codes for diseases like cancer and
coronary artery disease, the system was not designed to catalog medical errors.
Dr. Makary explained that no standardized medical statistics collecting system currently collects
incidence rates for deaths directly attributed to medical mistakes. The medical coding system was
designed to maximize billing for physician services, not to collect national health statistics, as it is
currently being used, he said. He added that medical errors are not caused by bad doctors or caregivers
but rather by systemic problems like poor care coordination, fragmented insurance networks, lack of
safety nets, and other widespread problems.

What About You?

Do your work duties include management of pharmacy compliance? Let us know.

The Coding Institute LLC, 2222 Sedwick Road, Durham, NC 27713, Eenterprise Contact: Sam Nair, Direct: 704 303 8150,
shyamn@codinginstitute.com

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Name: Sam Nair
Title: Associate Director Enterprise Practice
Email: shyamn@codinginstitute.com
Direct: 704 303 8150

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The Coding Institute LLC, 2222 Sedwick Road, Durham, NC 27713

The Coding Institute LLC, 2222 Sedwick Road, Durham, NC 27713, Eenterprise Contact: Sam Nair, Direct: 704 303 8150,
shyamn@codinginstitute.com