Deemed Status in Healthcare Accreditation
Deemed status is a concept that connects voluntary accreditation to mandatory Medicare certification. For CPHQ candidates, understanding deemed status is essential because it explains how accreditation programs serve a regulatory function in healthcare.
What Is Deemed Status?
When CMS grants an accrediting organization "deeming authority," it means that the accrediting body's standards meet or exceed the Medicare Conditions of Participation (CoPs) or Conditions for Coverage (CfCs). Healthcare organizations accredited by a body with deeming authority are "deemed" to meet Medicare requirements without needing a separate CMS survey. This is the practical connection between voluntary accreditation and federal regulatory compliance.
How Deemed Status Works
The process begins when an accrediting organization applies to CMS for deeming authority. CMS reviews the accrediting body's standards against the CoPs or CfCs to confirm equivalence or superiority. If approved, the accrediting body receives deeming authority for a specific type of healthcare organization. Hospitals, home health agencies, hospices, and other provider types each require separate deeming authority. Accredited organizations can then use their accreditation to satisfy Medicare certification requirements.
Organizations with Deeming Authority
Several accrediting bodies hold deeming authority for hospitals, including The Joint Commission, DNV GL Healthcare, the Healthcare Facilities Accreditation Program (HFAP), and the Center for Improvement in Healthcare Quality (CIHQ). For other provider types, organizations like the Community Health Accreditation Partner (CHAP) hold deeming authority for home health and hospice. CPHQ candidates should know that multiple organizations can hold deeming authority for the same provider type.
Validation Surveys
CMS conducts validation surveys on a sample of deemed organizations to verify that the accrediting body's survey process is effective. These validation surveys compare CMS findings with accreditation survey findings. If significant discrepancies are found, CMS may take action against the accrediting organization's deeming authority. This oversight mechanism ensures that deemed status remains a reliable proxy for Medicare compliance.
Key Exam Points
For the CPHQ exam, remember that deemed status is the mechanism by which accreditation satisfies Medicare requirements. Accreditation itself is voluntary, but Medicare participation (and thus compliance with CoPs) is effectively required for financial survival. Multiple accrediting bodies can hold deeming authority, and CMS validates their effectiveness through sample surveys.