The Centers for Medicare & Medicaid Services’ new survey process for long-term care facilities is set to start this November. The CMS mandated the new survey process through the agency’s final Reform of Requirements for Long-Term Care Facilities issued in November 2016.
Web2pro asked Patti Baicy, director of the clinical resource team at Web2pro Medical-Surgical, to identify the key compliance challenges created by the new survey process for post-acute care facilities and recommend the steps facilities can take to prepare for and overcome those challenges.
What is the purpose of the new survey process?
Baicy: The CMS will use the new survey process to determine the eligibility of a long-term care facility to accept and care for Medicare and Medicaid patients. It’s like Medicare’s Conditions of Participation for hospitals but for long-term care facilities. The new process revises performance metrics called “F-Tags” that measure a facility’s ability to provide safe, high-quality care to residents. CMS then uses the survey results as part of the criteria to determine a facility’s rating under its five-star rating system.
What was the previous survey process, and why did the CMS replace it?
Baicy: Actually, there are two different survey processes happening at the same time in different states. One is the traditional survey, and the other is the QIS, which stands for Quality Indicator Survey. The two are slightly different in terms of their focus on quality of care and quality of life issues. They also were different in terms of implementation—level of automation, sample selection, sample size, offsite reviews, onsite visits, survey structure and group interviews. The CMS said it wanted to combine the best of both previous surveys into one standardized national survey process.
What are the biggest differences between the new survey process and the previous ones?
Baicy: There are three big differences long-term care facilities need to be aware of. First, the surveyors will be using a tablet or laptop to record their findings rather than writing them down on paper. Second, the maximum sample size of residents whose cases will be reviewed will change. The maximum sample size was 30 under the traditional survey process, 40 under the QIS process and will be 35 under the new survey process. Of the residents to be surveyed under the new process, 70% will be chosen off site and 30% will be chosen on site. Third, the number of F-Tags will increase to 190 from 176. That said, 11 of the new F-Tags won’t be used by the CMS surveyors as performance measures until November 2019.
How should long-term care facilities best prepare for the new survey process?
Baicy: The number one thing would be education and training for the facility’s staff. The staff needs to be aware of the changes in the survey process, particularly the new F-Tags that the surveyors will be using to measure the facility’s ability to provide safe and effective care to patients. Two of the new F-Tags are infection prevention and antibiotic stewardship. That means a facility should have infection prevention and antibiotic stewardship programs in place and have the documentation to demonstrate the programs’ effectiveness to the CMS surveyors. Also, with the focus shifting to patient-centered care, the staff must know their residents and have their care plans in place within 48 hours of admission.
How can technology assist staff training and education?
Baicy: It’s critical for the facility to have a good EHR system that captures all the information on the care provided to residents. Embedded in the system should be a module or a capability that combs through all the information for risks. Not only is it important to show that the facility has policies and procedures in place on all the performance criteria, it’s also crucial that the staff has followed all the policies and procedures for each resident.
Other than education, training and documentation, how does a facility know it’s ready for a survey?
Baicy: After staff education and training, and after ensuring that its documentation capabilities are in place, the facility should do a mock survey. It should perform a survey on itself using the same survey that will be used by the state surveyor. It’s like taking a practice test to see if you’re prepared. The mock survey will flag areas that need to be improved and areas for which documentation needs to be improved. A facility may uncover a facility-wide problem or a problem on one floor, in one wing or with a specific group of patients. Then, education and training kicks in, or the documentation is improved to correct the deficiencies before the actual survey occurs.
When should a facility conduct a mock survey?
Baicy: Certainly, a facility should conduct a mock survey well in advance of the actual survey to identify and address any problems. Ideally, though, it should be an ongoing process. In other words, the facility is continuously monitoring its performance against the F-Tags and continuously making improvements. That’s made possible by the online survey tools that are available today. High-performing long-term care facilities make this an ongoing activity assigned to a specific staff member.
Any other pieces of advice for facilities to prepare for the new survey process?
Baicy: Yes. When the surveyors show up on site, a facility must make sure that its staff is prepared. That means the entire staff—from food service to maintenance to administration to clinical. Surveyors on site can talk to anyone who is in the building, including residents and families. The facility must address any problems before an onsite visit and make sure everyone is prepared through education and training. They need to know their residents and make sure they have a care plan in place within 48 hours of admission. We expect surveyors to spend more time onsite under the new survey process compared with the previous two survey processes.
Why does the new survey process matter to long-term care facilities from a business perspective?
Baicy: Facilities should take the new process seriously and adequately prepare for a number of reasons. First and most obvious is Medicare and Medicaid reimbursement. They also may face financial penalties if the survey results are below the acceptable standards for CMS. They could suffer an admissions freeze, also known as a bed hold, if they receive an Immediate Jeopardy (IJ) determination for substandard care. A low score on the new survey also can negatively affect the , which is public information. It can lose referrals from patients and families who choose facilities based on star ratings. And it can lose referrals from hospitals and doctors who are hesitant to send their discharged patients to poor-performing facilities. Good survey results are good business.