On December 2, 2011, CMS issued a new Survey and Certification Memorandum (S&C 12-08-NH) related to the Independent Informal Dispute Resolution (IIDR) Process for nursing homes. This memorandum replaces the original guidance that was dated October 14, 2011. Included in the memorandum are draft additions to Chapter 7 of the State Operations Manual which contain clarification to states about how the IIDR process must be managed and qualifications of the IIDR entity or person(s). The effective date of this process is for surveys that are initiated and ultimately have sanctions applied as of January 1, 2012. This change in the process can require that a provider deposit the entire amount of a civil money penalty into escrow at the time of the IIDR. This can have a significant impact on a provider because it may require payment of the civil money penalty at the time of the IIDR request. More details will be available as implementation of the changes occur.
You can get a copy of the CMS S&C Memo here —> S&C Memo 12-08-NH