By Shelby Grebbin
As operators face a difficult survey environment, collaborating with
other industry leaders – and trying to work with state survey agencies –
may be the key to staying in the green.
“As providers, I think it’s really easy for us to concentrate solely
on our company,” Kimberly Green, COO of Diakonos Group, said during a
recent Skilled Nursing News (SNN) panel on the skilled nursing survey
environment. “When we all realize that there are enough patients to go
around and that the industry is changing, we must all collaborate with
each other. Here, we want state agencies to collaborate … we really need
to see each other as peers and work together.”
In discussing how to improve the survey process so that it’s more
collaborative and productive for all involved, Green was joined by Tim
Fields, CEO at Ignite Medical Resorts, and Sonya Pusser, AVP of Clinical
Operations at American Health Communities. The panelists highlighted
examples of undeserved and avoidable citations, and suggested that those
involved with surveys return to using some of the practices, including
educational opportunities, of the pre-Pandemic era.
Diakonos recounted a specific incident where her team challenged a
survey finding all the way to the federal level, and the frustration her
team experienced when surveyors seemed uninterested in reviewing
documentation and partnering with providers.
“We are waiting to hear about that,” she said. “But when we were
trying to talk to the surveyor about it, and show them what was in the
documentation, they basically refused to even review it. It was like,
‘This is what it is, we’re moving on, you can deal with this,’ because
Immediate Jeopardy has a very specific process.”
Pusser echoed Green’s sentiments, citing instances of regulatory
misinterpretations leading to undeserved citations, despite her teams’
efforts to address compliance issues promptly.
“We find some of that in one of the smaller [regulations] that has
come to mind,” she said. “There’s the regulation related to labeling and
storage; well, it really just speaks to those medications that are
going to expire before the manufacturer expiration date. But then
they’ll come in and cite all these different medications that really do
expire at the expiration date.”
Yet she said that there are opportunities for improvement in
communication and collaboration between health care associations, such
as the Health Care Association and the American Health Care Association,
and regulatory bodies like the Health Commission, who can work on
behalf of providers to share insights and feedback, aiming for more
timely surveys, results, and follow-ups.
She said that before the pandemic, operators in Tennessee had an
educational forum on an annual basis where operators and surveyors could
ask each other questions.
“I think there are opportunities out there; we just have to get back
to doing that,” she said. “And they have to be willing to remember what
it was like. I think it’s helpful if the surveyors have some long-term
care experience to gain insight into what it’s like in a long-term care
facility.”
Regional variability
Regional variability in survey approaches across different states is
something that Ignite has to keep track of, Fields said, since they
operate in Wisconsin, Illinois, Indiana, Missouri, Kansas, Oklahoma, and
Texas.
“We’re seeing a form of [variability] in every single state,” he
said. “Again, I’m painting with a broad brush here on some really good
surveyors out there. There are some really good regents out there. Some
people have been very collaborative and fair to work with; some of our
higher-ups, you know, contacts at all the state levels, have been great
to work with.”
Such friendships with other multi-state operators, and amicable
relationships with surveyors, can help operators get a leg-up on
potential areas of concern, Pusser said.
“Where elopement might have been an immediate jeopardy years ago in
one state, it’s not now…It does seem to change as you move along,” she
said. “We do have some great surveyors who have that experience and
really do want to offer you assistance. They can’t give you
recommendations, but sometimes, if you respond quickly to certain things
and they know you’re going to address it, you might get that FYI.”
The panelists agreed on the importance of establishing proactive
communication channels with survey agencies, fostering mutual
understanding, and working towards shared goals of enhancing resident
care.
Regular communication and collaboration between providers and state
agencies proved beneficial, especially during the pandemic, Green said.
“The state would have weekly phone calls, and all the providers would
get on,” she said. “They would roll out any new regulations, any
changes, clarify for understanding, and ask if we had any input…Now, I
have to admit, initially, it was a running joke because it was basically
[state officials] were saying, ‘I don’t know, I don’t know, I don’t
know,’ to most of our questions. But it turned into a really great
Q&A where we learned together.”
Education opportunities for staff
Fields recommended utilizing the entire management team to address
patient and family concerns before they escalate to state involvement.
He also advocated for a concierge or hospitality model to engage
families directly and resolve issues internally, rather than having them
escalate to state authorities.
“We have to play in an environment where we’re guilty until proven
innocent,” he said. “And if we take that mindset and try to play offense
on this, there are a lot of things we can do on a daily basis.”
Ignite has implemented ‘Guardian rounds,’ where the entire management
team checks up on patients and families to make sure there aren’t any
issues, Fields said.
“I’ve heard from many state representatives that if they get called,
they can only come in once a year,” he said. “So, they’re not coming in
for an annual visit; they’re coming because somebody called them.
Preventing people from calling them is a good way to play offense.”
Pusser recommended attending educational sessions, developing
policies and procedures, and consistently educating facility staff.
“Come up with your internal plan on how you are going to make
adjustments within your education, policies, procedures, and electronic
health records (EHR) to be able to answer all the questions with the
updated Minimum Data Set (MDS),” she said.
Full Article & Source:
‘Guilty Until Proven Innocent’: How Nursing Homes Are Navigating a Tough Survey Environment
