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CHA Submits Comment Letter on Ligature Risk Guidance

For Chief Legal Counsel, CMOs, Licensing and Certification Staff, Quality and Patient Safety Staff

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CHA has submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) revised draft guidance on ligature risk policies for psychiatric hospitals and psychiatric units. 

In its comments, CHA urges the agency to clarify a number of areas. Specifically, CHA asks CMS to limit the scope of ligature resistant requirements to locked psychiatric units within psychiatric and acute care hospitals, and to remove references to emergency departments, which have resulted in significant confusion. In addition, CHA urges CMS to develop — with stakeholder input — extensive surveyor education on the guidance to ensure consistent and effective interpretation of the requirements. CHA also asks CMS to provide a number of clarifications on its ligature risk extension request process.