ARTICLE
5 Insider Tips on the New LTC Survey Process
Published Sept. 11, 2018
This article references Nursing Home compare data released on September 26th, 2018.
We are three quarters through 2018, and over half of U.S. nursing homes – 8,568 facilities – have been surveyed through the new Long Term Care Survey Process (LTCSP) so far.
The consensus? Many would say that the new survey isn’t that bad. In the past, about 10% of homes received civil money penalties (CMPs). So far with the new survey, only 8.3% have experienced a financial penalty. But keep in mind that everyone is still learning, which leads to the first tip:
1. Be aware of the current “honeymoon” period.
Along with mastering a whole new process, surveyors are also learning the new regulations and how to navigate survey software. But don’t let this learning phase catch you off guard. Continue taking a critical look at your actual performance throughout the year.
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2. Get control over Infection Control.
As I mentioned in a previous article, Tag F880 (Infection Control and Prevention) has been challenging for many homes. It’s been the most frequently cited tag by far, with 35.7% of facilities surveyed found to be noncompliant. To help avoid being tagged:
- Utilize the Infection Prevention and Control Facility task to audit your own program quarterly
- Regularly observe your staff to see how they perform infection prevention and control
- Remember that infection control extends beyond clinical care. Stay on top of possible issues with laundry, housekeeping and food service
3. Make person-centered care a central concern.
Based on the latest Nursing Home Compare data from September 26, 2018, the average number of deficiencies in the new survey is 6.6. Three of the ten most frequently cited tags focus on person-centered care:
- F656 (Care plan meets all resident needs)
- F684 (Appropriate treatment according to orders, resident’s preferences and goals)
- F550 (Honor resident rights regarding dignified existence and self-determination)
Be sure to conduct formal interviews with your residents so you can address concerns before surveyors arrive. Also, put a greater focus on your care planning meetings. Use the same Critical Element (CE) pathways surveyors use and check your work.
4. Tap into the power of preparation.
The Centers for Medicare and Medicaid Services (CMS) has made the new process very transparent. With initial pool assessments and investigative CE pathways published online, you have the potential to make survey an open book test. Use these tools to go through your own process, and you’ll find many issues to be easy fixes that can save you from in-depth investigations.
5. Gear up for Phase 3.
Phase 3 of the Final Rule won’t go into effect until November 2019, but that doesn’t mean you have downtime. Phase 3 requirements, including execution of QAPI, measuring and monitoring competencies, and trauma-informed care, are intense. Start implementing these changes now so you can work out the kinks.
Good luck – and remember – preparation is less costly than learning from your mistakes after survey. Put everything in place now, and you’ll sail through the actual process.
