Currently, you will find different variations of the survey process based on the state where you operate. Depending on where your facility is located, you find yourself preparing for the Traditional Survey process or a Quality Indicator Survey (QIS). However, the Centers for Medicare and Medicaid Services (CMS) will implement a new survey process nationwide during Phase 2 (effective Nov. 28, 2017) of the three-phase implementation schedule for the new regulations released in the CMS final rule entitled Medicare and Medicaid Programs: Reform of Requirements for Long Term Care Surveys.
At the first national American Association of Directors of Nursing Services in September 2016, Evan Shulman, CMS Deputy Director in the Division of Nursing Homes, Survey and Certifications Group, stated: “There are positive and negative aspects to both survey processes. The QIS is computer-based and can seem regimented. The traditional process allows the surveyor a little more flexibility. The new survey process leverages practices of both.”
According to the recent CMS slide deck and speaker notes previewing the upcoming changes to the long-term care survey process, the new survey process is an innovative computer-based, resident-centered process that balances structure and surveyor autonomy. Individuals who currently operate in a Traditional Survey environment will find surveyors utilizing a tablet or a laptop PC throughout the entire survey process and inputting their findings into a new software system. While this is current practice for QIS states, this is vastly different in our Traditional Survey states, where surveyors can be found walking the halls with clipboards and colored pens in hand.
In the new survey process, sample size selection will be based off of the facility census. Seventy percent of the total sample is MDS-preselected residents, and 30 percent of the total sample is survey-selected residents. Yes, you read that last sentence correctly: 30 percent of the total sample will be handpicked by the surveyors. Surveyors will pick their sample size based off of their observations, interviews and a limited record review.
Off-site preparation includes surveyors reviewing the Casper report as well as other facility history information. When surveyors hit the door, they will request a completed matrix for new admissions, an alphabetical resident census list, and a list of residents who smoke as well as the facilities’ designated smoking times. The surveyors will then begin observations with no formal tour process mandated by the new survey.
Observation will commence along with observations and limited record reviews. CMS has determined surveyors will take approximately eight hours on average for interviews, observations and screening. Surveyors now have the ability to ask questions to the residents however they deem most appropriate, whereas in the QIS survey process, surveyors were required to not deviate from the CMS-provided interview script.
Investigations, facility tasks and closed record reviews will be completed for the remainder of the survey using Critical Element Pathways to guide the investigations. Surveyors will now be required to participate in a Resident Council meeting with the active members within the committee as well as review previous council minutes.
According to CMS, active testing and validation is occurring throughout the country by contracted surveyors. Training on the new process for surveyors will begin at the regional offices level and then trickle down to the front-line state agency surveyors. Training for surveyors is occurring through various webinars and in-person training sessions. As of today, implementation of the survey process on a national level will occur on Nov. 28, 2017.
Providers can submit questions about the new survey process to the NH Survey Development mailbox at NHSurveyDevelopment@cms.hhs.gov. Information about the survey process and implementation can be found at: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes.html
References: New Long-term Care Survey Process – Slide Deck and Speaker Notes [PPTX, 8MB]
By Christine Aliberto, Director of Clinical Services, Mission Viejo, CA