CMS – SIA Projects

SIA Independent Peer Review Team and Onsite Consultant(s)

CMS initiated the Conditions of Participation for Organ Transplant programs on June 28, 2007. Five of the 500+ Medicare Certified organ transplant programs were found to have "significant deficiencies that affect or had the potential for affecting the health and safety of transplant recipients and living donors". These centers completed a rigorous retooling mandated under an agreement with CMS referred to as a Systems Improvement Agreement (“SIA”) to avoid losing Medicare certification.

Since then, many more transplant programs have entered into SIAs with CMS. In addition to these programs, several requested and received consideration due to "mitigating factors" to elude the issuance of a Statement of Deficiencies.

Guidry & East has assisted approximately one-third of the centers cited under the Conditions of Participation. This entailed the furnishing of six-person Independent Peer Review Teams and the insertion of an onsite independent Quality Consultants for eight to ten days a month for the term of the Systems Improvement Agreement (generally one year).

If your program receives an SIA, you will be required by CMS to follow very tight time-lines associated with the Agreement. Guidry & East has a committed team of transplant professionals with the experience to work with you and CMS in developing a Root Cause Analysis Report, the subsequent Corrective Action Plan, and provide the onsite independent Quality Consultant required to assist the hospital with improving patient and graft outcomes and implementation of the recommendations brought forth by the Independent Peer Review Team.