CMS Nursing-Home Survey Replaced Annual Survey, Provided Window into COVID-19 Operations
November 17, 2020
Nursing home operators are familiar with annual surveys from the Centers for Medicare & Medicaid (CMS)—they, like everything else, have been changed significantly in 2020 due to COVID-19. In March 2020, CMS revised its survey process to one that targeted facilities with a history of infection control issues or those that had suffered an outbreak of COVID-19. The new survey was shorter, which limited the time CMS personnel were in the facility, and also reduced the time staff would have to spend away from patient care. In addition to outlining where the facility was with COVID-19 preparedness and its ability to prevent transmission, the new self-assessment process also aligned with guidelines from the Centers for Disease Control (CDC) to perform voluntary assessments, according to Robin Harper, RN, a former surveyor and survey trainer who worked at CMS in its division for nursing homes as well as the division for chronic and post-acute care.
“The survey tool provides a focused review of seven critical elements that are associated with the transmission of COVID-19,” explained Tracy Cooley, a former surveyor and survey trainer who also has served as a Director of Nursing in a skilled-nursing setting. The COVID-19 survey activities can be broken into sections, such as pre-survey planning. These include, but are not limited to, active COVID-19 cases, in which case the survey team will contact the state health department and CMS regional office to coordinate the survey activities.
“For example, in certain cases, those agencies may ask the survey team to delay entering your facility until the department of health or CDC has assessed the situation,” she says. “Surveyors will obtain information such as facility-reported information or CDC, state, local and public health reports, or any available hospital information regarding residents transferred to the hospital and complaint allegations.
They're going to identify the surveyors who will remain offsite to receive information from the one to two surveyors that are going to be onsite, determine which survey activities will be conducted onsite and which will be conducted off site with a plan for as doing much as much offsite as possible,” she says.
Once onsite, the surveyors will notify the administrator of the limited nature of the COVID-19 focused survey. They'll conduct an entrance conference using the COVID-19 entrance conference form developed for this type of survey, Cooley says.
On-Site Observations Prioritized around Compliance to Transmission Protocols
Another key element of the visit will be a close look at prevention basics, adds Harper, pointing out that facility staff can become complacent without meaning to do so.
“It's nice to have a tool like this, because it reminds us of those critical components of our infection control practices that we really might not think about day to day now, more than ever,” Harper says, “The very first question that's on the self-assessment is, ‘Does the staff implement appropriate standard and transmission based precautions?’ So how are we ensuring that the staff understand and are compliant when it comes to some of these areas? You may be seeing some breakdowns right now regarding infection control measures, such with hand hygiene, disinfecting equipment and use of PPE.”
To combat that, and ensure the best possible care to residents, administrators need to recognize that staff is tired, scared and in need of positive feedback. They may also be nervous about being questioned by outside surveyors.
“If you've already been asking these questions of your staff, then it's just routine,” Harper points out. “And it also helps validate your assurance of their knowledge.”
Those efforts should then be married to care protocols for residents who test positive for COVID-19, as well as policies and procedures for visitor entry, communication to residents’ families and other people-oriented activities.
HealthStream works with organizations throughout non-acute care to address their challenges, from keeping pace with regulatory requirements to engaging and developing competent staff who can satisfy the demands of increased patient complexity. By partnering with HealthStream, organizations are equipped to seamlessly manage the pressures of surveyor visits, while remaining focused on high-quality patient and resident care. Learn more about HealthStream solutions for non-acute care organizations.