After some stops and starts, surveys of hospital compliance with the Medicare conditions of participation and other regulations are returning to normal, more or less. In a March 26 memo^[1] to state survey agency directors, CMS said “all onsite revisits are authorized and should resume.” Surveys have been limited mostly to infection control and immediate jeopardy (the risk of death or harm to a patient) during the COVID-19 public health emergency (PHE). Now they’re opening up, and the usual rules on plans of correction again apply, according to the memo from the directors of the Quality, Safety & Oversight Group and the Survey & Operations Group. Because of the PHE, however, there is some flexibility in the process.

“I would expect to see more surveyors in person in hospitals and other health care facilities because of the significant increase in vaccinations and the numbers of COVID-19 cases trending down,” said Mary Ellen Palowitch, former EMTALA technical lead in the CMS Quality, Safety & Oversight Group who is now with Dentons US LLP in Washington, D.C. “But if we go back and have another surge, things will probably be put on hold again.”

It’s been a roller-coaster year for surveys. CMS sought to give overwhelmed hospitals, nursing homes and other providers a break without sacrificing the quality improvement and safety mission of surveys performed by the state and accrediting organizations, especially in the area of infection control.