Every home health agency and hospice agency that receives reimbursement from Medicare and Medicaid understands the anguish a CMS survey can cause. There’s a lot on the line; if you can’t prove you meet each of your Conditions of Participation (CoPs), you risk losing CMS certification altogether.
Fortunately, with the right strategy in place, you can not only survive the survey process, you can come out shining.
The challenge, of course, is that you don’t have the luxury of knowing when the state surveyor will show up at your door. Advanced preparation, therefore, is critical. The more you understand CMS requirements, the easier this will be.
Know Your CoPs Inside and Out
The CoPs spell out the requirements for acceptable quality in your operations. Your State Survey Agency acts on behalf of CMS to ascertain whether and how well your agency meets each quality standard. The CoPs also contain interpretive guidelines that explain the standards; they’re not statutes per se, but they can help clarify what the surveyor will be looking for in your performance and practices.
Take the time now to read through every single CoP and guideline that impacts your agency. Go through each one and identify precisely how your agency complies with it. Understand which chart corresponds with which guideline, where to find it, and who is responsible for it. If you don’t know, note it and fix it so that you do.
Anticipate What the Surveyor Will Ask
One of the first things the surveyor will ask for is your current census. Based on these numbers, the surveyor will be required by CMS to review a certain number of charts. The surveyor will randomly select these charts; you can’t cherry pick the ones you want the surveyor to see, so all your accounts need to be review-ready at any time.
Understand, too, that the surveyor will be thorough, with a pre-defined methodology and a detailed checklist to make sure your CoPs are met.
If you can quickly demonstrate that every service your agency provides is carefully documented against a care plan, and that all patient and staff files are meticulously maintained, the surveyor will quickly understand you have a comprehensive compliance strategy in place – and your day will go a whole lot smoother.
Make Sure Documentation Is Accessible
A key factor in ensuring your CMS survey is successful is to have the information your surveyor needs readily available.
This can be a challenge for agencies that rely on paper documentation, which may mean physically pulling charts and rifling through files. Worse, if the surveyor asks for something you can’t produce immediately, you could be in trouble. Do you make the surveyor wait while you scramble and search? Do you tell the surveyor you’ll get back to her? Neither option is great for you.
On the other hand, agencies that leverage electronic recordkeeping and point-of-care documentation typically fare much better. For these agencies, any record the surveyor requests is available with just a few keystrokes. This sets an entirely different tone to the survey, and it lets the surveyor know her job will be much easier with your agency.
Think Through Your Processes
Because you never know when your agency will be surveyed, preparing in advance will ensure you’re ready at a moment’s notice.
Conduct spot checks and periodic documentation audits to verify your care providers are documenting everything they should be. Better yet, implement an electronic documentation system that alerts you if a staff member does not complete a specific task, so you can correct the situation in real time.
Additionally, think about what happens if the surveyor shows up on a day you’re out sick? This is a real risk. The right solution is to make sure everyone in your office knows exactly what to do during an audit.
Consider creating an internal instruction set that identifies the information the surveyor will need and how to get to that information quickly: which reports to run, which binders to pull, which mandatory documents to print. Keep these instructions on a shared drive or other handy location so that anyone in the office can react quickly if a surveyor should drop in unexpectedly.
Conduct a Practice Audit
The more comfortable your staff are with the idea of an unexpected survey, the better everyone will do when the real thing happens.
Just like the fire drills you practiced in school, conduct a practice audit to walk through the entire process. Have someone pretend to be the surveyor, and using your CoPs and interpretive guidelines as your template, have that person ask the staff to produce certain items. Switch roles, until everyone knows exactly what to expect and can perform flawlessly.
You can even include survey readiness in your regular internal staff communications. One hospice agency includes articles such as “Top 10 Things to Know During a CMS Survey” in their monthly newsletter.
After all, readiness is your best shot at zero deficiencies in your survey results.
Be Ready to Answer Questions
After the surveyor reviews your documentation, she will want to talk to your staff – particularly, your field staff who deliver the care and interact with clients or patients.
This can be nerve-wracking for some people. It’s helpful, therefore, to practice these interviews ahead of time as part of your audit process, so staff members know what to expect and can practice how to answer different types of questions.
Additionally, during the actual interview, ask if you or another manager can be present in the room. You’ll need to be quiet and let the staff member answer the surveyor’s questions, obviously, but even your silent presence can be reassuring for that person.
This also gives you the opportunity to take notes about issues raised during the survey, so you can follow up on these issues quickly.
In Closing…
Succeeding with a CMS survey requires knowing your quality standards, knowing your documentation, and knowing how to answer a surveyor’s questions quickly and completely. You need to be able to explain why your agency does what it does, and how those practices meet your regulations.
With the right documentation processes and compliance validation system in place, your agency will sail through your next survey without so much as a hiccup. A proven care delivery management partner can help you identify best practices to improve your current operating procedures.
To learn more, contact CellTrak today – and never worry about your next CMS survey again!
