On June 7, 2000, the Health Care Financing Administration (HCFA) issued a set of questions and answers (Q & As) on long-term care enforcement policies and procedures found in Chapter 7 of the State Operations Manual (SOM). This publication contains Q & As numbered 17 through 28. This new set of questions is available by calling 1-888-890-8422, then requesting fax on demand #704.

Regarding question #18, contrary to previous statements, HCFA states that past noncompliance cited at F Tag 698 will be considered in computing the “double G” violations for identifying facilities that will not have an opportunity to correct before enforcement remedies are applied. As HCFA explains in question #19, the “double G” calculation uses noncompliance that is identified between periods in which the health care facility was in substantial compliance. According to the Long Term Care Enforcement Procedures on pages 7-64, facility noncompliance identified between surveys is entered on the HCFA-2567 at Tag 698 at the bottom of the form. The dates of the past noncompliance are noted in the summary statement of deficiencies.