CMS issues new protocol for identifying Immediate Jeopardy
By Allison Shelton and Beth Anne Jackson, Brown & Fortunato, P.C. On March 5, 2019, the Centers for Medicare and Medicaid Services (CMS) issued new guidance relating to “Immediate Jeopardy” (IJ) determinations. The instructions for such determinations that had been in place since 2004 in Appendix Q of the State Operations Manual were overhauled by CMS. Appendix Q guides surveyors in the determination of IJ situations, which is the most serious citation that may be...