CRISP Reporting Requirements
OHCQ will impose CMPs for non-reporting to CRISP
As you know, nursing homes are required to report specific COVID-19 information on a regular basis. The most recent MDH order dated August 18 requires nursing homes to report certain information on a daily basis, as well as vaccination information on a weekly basis. Per this just released transmittal from the Office of Health Care Quality (OHCQ):
In the past two weeks, a third of all nursing homes failed to report to CRISP on one or more days. Given the importance of this data, the continued failure of facilities to report, and the potential for more than minimal harm, OHCQ will cite nursing homes for each day of non-compliance. Every two to four weeks, OHCQ will review the nursing homes for whom CRISP reporting data is missing to determine if there are extenuating circumstances that prevent a nursing home from submitting the required data.
In the absence of extenuating circumstances, a State civil money penalty will be imposed for non-reporting to CRISP. To decrease the facility’s administrative burden of submitting a plan of correction and OHCQ’s review of the facility’s plan, OHCQ will impose a directed plan of correction (see page 3).
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First deficiency: $2,500 State CMP per instance of day of not reporting with a directed plan of correction. For example, if the facility does not report 3 days of the two-week period, the CMP is $7,500.
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Second deficiency: $5,000 State CMP per instance of day of not reporting with a directed plan of correction. For example, if the facility for a second time does not report 3 days of the two-week period, the CMP is $15,000.
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Third deficiency: $7,500 State CMP per instance of day of not reporting and $7,500 for a quality assurance performance improvement deficiency with a directed plan of correction. For example, if the facility for a third time does not report 3 days of the two-week period, the CMP is $30,000.
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Fourth deficiency: $10,000 State CMP per instance of day of not reporting and $10,000 for quality assurance performance improvement deficiency with a directed plan of correction. For example, if the facility for a fourth time does not report 3 days of the two-week period, the CMP is $40,000.
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Fifth deficiency: A directed plan of correction will be imposed that requires the nursing home to hire a consultant to collect and submit data to CRISP.
Note that OHCQ may perform an on-site survey at any time to verify a nursing home’s compliance with regulations and requirements. If you have any questions or need additional information, please contact at tricia.nay@maryland.gov.
