Smart Approaches to Improving the Performance of Continuing Care Organizations
Clinical Issues
CMS State Operations Manual
State Operations Manual This site contains downloads of the CMS State Operations Manual for SNFs. This manual includes the survey process and guidance to surveyors.
Appendix P This appendix contains the state survey protocol for skilled nursing facilities.
Appendix PP This site includes the interpretive guidelines for surveyors for long term care facilities. These guidelines are useful in preparing for survey.
Surveyor Guidance Changing on September 1, 2008 on Nutrition and Sanitation F-Tags
The guidance to surveyors for nutrition and sanitation are changing effective September 1, 2008. Several F-tags have been merged, although the regulations remain unchanged. The surveyor guidance has been updated to help surveyors investigate noncompliance and to assess severity.
To read an advance copy of the CMS transmittal announcing these changes, as well as the training slides used to prepare surveyors to apply the changes, CLICK HERE and download the PDF document.
After reading these documents, you should consider:
Gathering your clinical team to review the assessment and care planning elements of the regulations and determine if your policies and procedures are current
Use your MDS data to review the clinical documentation of any residents who have triggered for weight loss and review the documentation in the light of the new guidance
Review the standards for sanitation and determine if your policies, procedures, and practices in food storage and preparation areas are in compliance
At your next infection control or quality assurance committee meeting, review the sanitation guidance and consider changes that may be needed in your infection control manual
These strategies should be considered in addition to your usual survey preparation activities.
Going Through Survey is Like Going Through a Speed Trap
Going through an annual certification survey for a director of nursing or administrator of a nursing home is the equivalent of going through a speed trap. No matter how well you care for your residents throughout the year, if the surveyors find an issue during their visit, the facility is likely to get a deficiency. The job of surveyors is to ensure that a facility is compliant with minimal standards for certification, and their process is based on a sampling approach. It can be inferred that finding a problem in a sample of residents can mean that the same problem occurs in the facility as a whole. They do not have the time or resources to validate that assumption with a review of each and every resident. It is the responsibility of the surveyors to the government and to consumers to ensure that these standards are met. This can be compared with the analogy of the police officer who catches you in a speed trap. He or she does not know how good or bad a driver you are or have been. All they know for certain is that at a given point in time they caught you not being a good driver.
If you keep this concept in mind, it will help you prepare for the annual certification survey and hopefully go through it successfully. To start with, you must be a good driver to reduce your chances of getting caught in a speed trap. While even the best drivers occasionally get caught speeding, their chances of getting caught are much less than those who speed all the time and don't care. The same is true of surviving the survey-- you must give good care to reduce your chances of getting a deficiency. All the survey preparation in the world is not going to help you if you really do have quality of care issues. And if you do have serious quality of care issues, for the sake of your residents and the reputation of the industry, you probably should get deficiencies.
There are ways of avoiding getting caught in speed traps. These include keeping an eye on your speedometer, using cruise control, using a radar detector, and asking your driving companion to remind you if you get over the speed limit. Likewise, you can avoid deficiencies during a survey by monitoring the care you deliver throughout the year with a good QA program, by keeping track of your quality indicator reports and your triggers/flags, by scanning the professional environment (other facilities, trade associations, etc.) for information on latest trends in surveys, and by having an consultant perform a mock survey review to see how the care looks to an objective set of eyes.
Everything you knew about the survey process...but forgot! Consultant Sharon Carlo has worked in long term care as an administrator and director of nursing, a consultant, and as an administrator for a state health department's survey process. Listen to her engaging 50 minute audioseminar on the nuts and bolts of preparing for a successful survey by clicking on the MP3 icon to the right.
Diagnostic Review in Preparation for Annual CMS Certification Survey
In order to ensure that you are prepared for your annual certification survey, you should consider having an outside consultant conduct a diagnostic review of your facility. Following this on-site review, the consultant will provide your staff with feedback on areas that may need additional attention based on observations or data review. I provide this service throughout the country, and would be pleased to have the opportunity to send you additional information...just fill out and send the information on the form below, and I will contact you.
