PROVIDIGM | News & Blog
Getting Ready for the New LTC Survey
Top Three Things to Do
Ellen Kuebrich, Chief Sales and Marketing Officer
January 31, 2018
On November 28, 2017, Phase 2 of the CMS final rule on long-term care (LTC) reform took effect, marking the most substantial overhaul in nursing home regulations in 25 years. In addition to this significant regulatory change, CMS is also implementing a new survey process that will impact all Medicare- and Medicaid-participating LTC facilities. The new Long Term Survey Process (LTCSP), often called the hybrid survey, incorporates aspects from both the traditional survey and the Quality Indicator Survey (QIS).
If you haven’t already started, now is the time to begin preparing for the new LTC survey. The challenge facing many LTC leaders is how? It’s not as intimidating as it may seem, but be sure to devote adequate time and resources to the process.
Below are three actionable steps that you can take today to begin preparing for the survey:
1. Understand the new survey process.
It’s important to understand the survey, as well as the rationale for the change in survey process. The two previously used survey processes focused on slightly different quality of care/quality of life issues, and surveyors identified opportunities to improve the efficiency and effectiveness of both survey processes. In addition, it was expensive for CMS to run two survey processes. You can imagine that given the scope of the regulatory reform, it would have been prohibitively expensive to develop two sets of training, adjust two sets of documentation and incorporate new requirements into two different processes.
Instead, CMS set out to create one efficient and comprehensive survey that gives surveyors more of the leeway they enjoyed in the traditional survey, while benefitting from the structure and comprehensive nature of the QIS. Similar to QIS, the new LTCSP will cover all areas of care in the regulation in a standardized and computerized format. The LTCSP also will utilize the Critical Element Pathways that were developed for QIS, although these pathways are now updated to reflect changes from the final rule.
In contrast to the QIS, the LTCSP will not use statistical thresholds to determine what areas get further investigation. Rather, this decision is left up to the surveyors and is made after an Initial screening-, structured Resident Interviews, Family Interviews, Resident Observations and limited closed-record reviews. The screening questionnaires will cover every care area, and the responses garnered will determine whether the surveyor investigates each care area further.
2. Consider your readiness strategy.
The first step to preparing for the new survey is to examine your existing survey-readiness strategy. Do you have a way to collect data on every area of care through interviewing and observing your residents? As you consider your strategy, be sure to view everything through the resident’s eyes. The new survey process is similar to QIS in that it is very resident-centered; resident-specific concerns are identified through resident observations and resident or representative interviews. Before the survey, work with and interview all staff, residents and families to become familiar with and address their viewpoints.
In addition, the published thresholds from QIS—although not used in this new survey—still present a data-driven way to predict issues that have a high likelihood of further investigation. You can also utilize the published Critical Element (CE) Pathways to your advantage. These in-depth investigation protocols that your surveyors will use for each care area are publicly available. Use the same pathways when investigating your own compliance.
Also consider that high-risk care areas such as Abuse, Pain, Dental, Pressure Ulcers and Accidents will be investigated if any Initial Pool resident gives a negative answer. As such, it’s a safe strategy to assume that all areas will be investigated and run through the CE Pathways ahead of time.
Finally, keep in mind that collecting feedback from residents, families and staff is now a requirement under the Quality Assurance and Performance Improvement (QAPI) regulations. There’s no sense doing double work; consider periodically conducting interviews and collecting observations that will cover all care areas and you will be conducting QAPI while remaining ready for survey.
3. Make sure that your Phase 2 “homework assignments” are ready.
As of November 28, all LTC facilities are required to have a QAPI Plan and Facility Assessment completed. Your survey Team Lead will ask for these documents in the entrance conference, and you will have four hours to provide them. These should be complete and ready for review prior to survey entrance. It’s also a good idea to review the Entrance Conference Matrix so that you are aware and prepared with the other items that your surveyors will need in the first four hours.
The new survey process will be a learning experience for surveyors and providers alike. Coupled with the extensive new regulation, this year’s surveys will likely be a challenge for all parties. Remember, the reason CMS has surveys is to ensure that we are giving good resident care, which is also our goal as an industry. Being proactive in your survey readiness for this resident-centered survey will not only help your survey performance, but will also help you to constantly have an ear to the ground on how to improve care for your residents.