LeadingAge has recently heard from several members regarding unannounced visits by contractors for the Centers for Medicare & Medicaid Services (CMS) being made to nursing homes. These visits are related to Medicare provider enrollment and revalidation, and though they feel suspicious, they are legitimate. We are working with CMS to improve processes. In the meantime, we have compiled the information below to help you identify these visits and know how to respond.

What We Are Hearing From Members

These visits are unannounced. A CMS contractor arrives at the nursing home without any prior notification to the nursing home and requests to take photographs. The contractor has a badge, but it is for the contracting company, not CMS. The contractor also has a letter from CMS explaining the purpose of the visit, but we are hearing that some contractors do not show this letter unless asked. Neither the contractor’s badge nor the CMS letter can be photographed. However, the letter contains a QR code that can be scanned for more information.

While some contractors are able to clearly state why they are there, we are hearing that some contractors are not. They may say things like, “I am here to verify operations,” or “I am here for compliance.” When challenged, we are told that some contractors remind the nursing homes that failure to admit entry could result in termination of the provider agreement. Some of our members tell us that when they have reached out to the State Survey Agency or the CMS regional office to verify the contractor’s visit, neither the state agency nor the CMS office are aware of the visit or able to provide additional information.

Once permitted entry, we are told the visits are rather quick, with contractors verifying licensing information and taking photographs of the nursing home, in which they take care not to include residents. This may include, however, the need to temporarily relocate residents from common areas including therapy gyms and hallways.

What We Know from CMS

Site visits are conducted to verify operational status as part of provider enrollment and revalidation. Site visits are contracted out by CMS to two Site Verification Services Contractors and their subcontractors:

In the east, site visits are conducted by Palmetto GBA and its subcontractors:

• Overland Solutions, Inc., an affiliate of EXL
• Information Discovery Services
• Compliance Review, Inc.
• National Creditors Connection, Inc.

In the west, site visits are conducted by Deloitte Consulting, LLP and its subcontractors:

• Nationwide Management Services, Inc.
• CSI Companies, Inc.
• Arthur Lawrence Management, LLC
• Computer Evidence Specialists, LLC

There are two types of site visit. One is an observational site visit, during which the contractor will take photos but will have minimal contact with the provider. The second type of visit is a detailed review. During the detailed review, the contractor will speak with staff and collect information to confirm compliance with Medicare standards. In both circumstances, the presenting contractor will have a badge/ID and a letter from CMS. The badge and letter can be reviewed but neither can be retained or photocopied.

What We Are Doing and What You Can Do

LeadingAge is working to improve the experience of these visits by raising awareness among members. We are also working with CMS to improve processes. We have discussed with CMS why these visits feel so suspicious to nursing homes and asked them to educate contractors on why nursing homes may be reluctant to provide entry. We have asked that contractors be better educated on how to explain the purpose of the visit, including using language that is familiar to the nursing home provider.

Nursing homes should make sure that staff, including any Front Desk or Concierge staff, are aware of these visits and the nursing home’s internal protocols for how to handle them. When a contractor arrives, ask to see their badge and the CMS letter. Remember: you may review the badge and letter but you may not retain them or photocopy them. To verify that these visits are legitimate, contact your Medicare Administrative Contractor.