Because you are bright and shiny home health employees with enthusiasm to spare, it goes without saying that you are ready for survey all day, every day. But just in case you fell behind, here’s a few tips on being ready when those cheerful surveyors come calling.
- Make sure your annual advisory meeting is held timely. There is nothing you can do when it’s time survey and your PAC meeting is six months late.
- Get your CLIA waiver updated if it within three months of expiration. If it is current, put the expiration date on your calendar with a reminder three months from the date.
- Plans of care for all patients should be current and updated and reflect the actual needs of your patients – not just what the computer thinks.
- Medication lists should be current. Obviously, you and your colleagues are checking meds on every visit but just in case it never hurts for the DON or QA nurse to spend an afternoon doing supervisory visits and checking medications. If meds are okay, relax. If you find errors, implement an agency wide plan to have the meds of all patients reconciled within a week. After the initial medication campaign, follow up.
- Do the QA thing. At a recent Home Care of Louisiana meeting, the state agency responsible for whipping home health agencies in line gave a presentation about what they were finding on surveys. Although tags were not frequently issued for Quality Assurance plans, almost every other tag could have been prevented by reading notes as they came into the agency against the plan of care. Consider the difference between seeing a missed visit cross your desk compared to a chart with numerous missed visits. You must read your charts if you want to know what is in them.
- Most importantly, call the physician. Almost every survey with deficiencies includes at least one tag resulting from a change in the patient’s condition that was not communicated to the physician. I have spoken with nurses who are unwilling to call physicians because they have been chastised in the past for ‘bothering’ physicians. Communication is not the same as harassment. If you reserve phone calls for emergent situations and fax or secured email for updates, everyone can be on the same page without overwhelming the physician.
- Consider a coding company. Although the primary purpose of The Coders is to ensure correct ICD-10 codes and OASIS responses, a registered nurse reviews the clinical records to determine what those codes and responses should be. So, while we don’t specifically look for QA indicators, we notice the more serious omissions and make note of them for the agency. Another side effect of a Coders contract is that our coders notice when assessments are incomplete or late. Getting caught up can make an enormous difference for agencies with a backlog.
Notice what is not on the list. There is no minimum standard for face-to-face encounters. Surveyors may comment about excessive lengths of stay but rarely is a tag issued for redundant teaching or failure to provide reasonable and necessary services. The state agencies do not pay your bills. The hoops you must jump through for payment are in addition to the minimum standards for your state.
Some of you may know some people at an agency that is utterly unprepared for state survey. If this is a long-standing problem, there is probably not much they can do in a short period. On the upside, in the absence of patient harm and extreme irresponsibility on the part of the agency, the state will allow for an opportunity to clean up any messes in the form of an action plan. Or they can pay a consultant to come in and have them write an action plan. We prefer the latter but you won’t receive an invoice from the state surveyors. Just saying.
Here’s what you don’t do. Don’t call a consultant in the weeks before survey is due and expect them to make the changes required for a flawless survey.