How To Get Through a Survey
And Avoid $30,000 per day in Civil Money Penalties (CMPs)
By Kathie Kane
At this year’s annual conference, attendees heard in-depth
information from the state Department of Health about the
survey process and what to expect in the upcoming weeks,
months and years.
In their session, Worst-Case Scenario Survival Handbook –
State Survey Edition, presenters Elliott Frost and Sherrie
Turano of LeadingAge New York ProCare illustrated concrete
strategies for staff to make the survey process easier and
more successful.
By the time the time the surveyors are in your building,
everything you have done to that point to prepare for the
survey will determine the outcome. Have you measured your
side rails and mattress height? What is your plan to reduce
antipsychotics? How are grievances handled and who is your
grievance officer? Review the Phase 1 requirements and fix
any you’re struggling with before surveyors point them out.
In other words, the time to detect and correct your own
problems is before the surveyors arrive!
What is the Centers for Medicare and Medicaid Services
(CMS) Strategy?
1. Enhance Customer Awareness
2. Strengthen Survey Processes, Standards and Training
3. Improve Enforcement Actions
4. Promote Quality Improvement
5. Create Strategic Approaches Through Partnerships
Of these, numbers 2, 3, and 4 are the hottest issues.
SURVEY READINESS AND MANAGEMENT
Yes, there is little consistency from surveyor to surveyor
and from region to region but you need to know what is
expected in your region from your surveyors. Training staff
is your best defense. Be on the floor when the surveyors
are in the building. You can’t hide from them and even when
they are reviewing charts and reading your policies; they
are listening – to your staff and residents. It’s a good idea
to prepare your staff to say “Let me get that information
for you” or “I can get the staff member who has that
information to speak with you” when they don’t know the
answer to a surveyor’s question.
COMING IN THE SUMMER OF 2017
Starting this summer is a new survey process where
70 percent of the samples will come from software
and 30 percent will be identified by the surveyor. There
will be a heavy reliance on interviewing – leading to
more fact finding. This is where training, mock surveys
and preparation will work in your favor.
PREVENTION VERSUS REACTION
The best way to get through your next survey is to
prepare, educate and implement. Are you doing internal
mock surveys? Have you thought about crossing over
departments? Don’t have your nursing staff review your
nursing staff. Rather, cross over and have your activity
therapy staff review nursing and compliance and your nursing
staff review your food service compliance. Sometimes when
you live and breathe a job the way staff does, it is hard to see
the little (and big) problems in front of you every day.
Contact your ProCare representative for more information
on how to prepare for your next survey and you too can save
$30,000 per day in CMPs.
CMS
Enhance Customer Awareness
Strengthen Survey Processes,
Standards and Training
Improve Enforcement Actions
Promote Quality Improvement
Create Strategic Approaches
Through Partnerships
One answer they should not give is: “I don’t know” or “that’s
not my patient.”
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Adviser a publication of LeadingAge New York | Summer 2017