Accreditation Resource Services Newsletter
June 2020

CIHQ-ARS Blog

Contract Services - Part One

By: Traci Curtis
Welcome to the first in a four part blog series on CMS' expectations for managing contract services in a hospital. In this blog, we're going to discuss developing a list of contract services.
CMS Conditions of Participation at §482.12(e)(2) require that your hospital maintain a list "of all contracted services, including the scope and nature of the services provided." Notice that the language states "all" contract services - not just patient care contracts. Hence, CMS - unlike some accrediting organizations - occasionally surveys contract services that have little bearing or impact on delivering safe or quality patient care.
Notice also that CMS requires that the list itself - in addition to the contract – outline the scope and nature of the service provided. This does not mean that your hospital must copy/paste detailed information from each contract onto the list, but there should at least be a bullet point high-level description provided. See the example below:
Name of Contract Service Description of Scope & Nature
ABC Dialysis Company Short term inpatient acute dialysis
In addition, the list should only include those contract services that are physically provided on-site at any of your hospital's locations – including off-site settings. Remember that CMS does not survey contractual relationships where the patient is sent to a care setting that is not billed under your Medicare provider number.
In preparing the list of contract services, organize the document according to the impact a contract service has on patient care. While not required, it can be helpful to your hospital in prioritizing the resources necessary to effectively monitor the services. Consider organizing the list as follows:
Direct Patient Care Contracts
These are contracts for services that directly provide patient care. These types of contracts are most frequently reviewed by CMS. Common examples include supplemental staffing, dialysis, and imaging services such as lithotripsy.
Indirect Patient Care Contracts
These are contracts for services that - while not providing care - directly support those who do. These types of services are also frequently reviewed by CMS. Common examples include environmental services, food services, biomedical services, and transcription.
Non-Patient Care Contracts
These are contracts for services that do not directly or indirectly impact patient care. CMS does not usually review these services, but can if they choose to do so. Common examples include billing, landscaping, and non-patient care supplemental staffing services.
Once your list is generated, have it reviewed on an annual basis to assure it reflects the current services provided by contract entities. Lastly, assure that the list is available to surveyors on request.
Join me for our next blog as we discuss written agreements for contract services and CMS' expectations in this area.
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