On October 5, the Centers for Medicare & Medicaid Services (CMS) issued memorandum QSO-21-01 Hospice– “Nursing Shortage as an ‘Extraordinary Circumstance’ per 42 CFR 418.64 CORE SERVICES” to State Survey Agency Directors. CMS has issued memoranda authorizing use of contracted staff under extraordinary or other non-routine circumstances as authorized under the “extraordinary circumstances” core services provisions at 42 CFR 418.64 on a regular basis over recent years based on the ongoing nursing shortage. The most recent memo, issued in 2018, was applicable through September 30, 2020. The October 5^th memo does not have an expiration date for the authority and does not explicitly limit the use of contract staff to nursing so could be used, when applicable, for counseling and social work staff as well as long as the other requirements of the guidance are met.

Questions?

Contact:

Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services
c: 425-231-4804