Payment and Policy: Surveyors turn attention to activities guidance: Expert

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Providers should stay on guard, even if they haven't yet felt the heat from 18-month-old activity and psychosocial surveyor guidance.

Some areas of the country already have seen aggressive interpretation of the requirements, and surveyor vigilance should only increase, warned Catherine Selman, president of The Healthcare Communicators Inc., and one of the authors of the revised guidance.

"I've been telling people not to get complacent. What I fear is people will say it was all a lot of brouhaha about nothing and that it will just go away," Selman said.

The new guidance, encompassing F-tags 248, 249 and 250, went into effect in June 2006. During its first six months, there was not much citation activity, Selman said.

"They seemed to be looking at everything much closer (this year)," she added. "They were very consistent at what they were looking at. We saw double-G citations in some states."

Enforcement has been uneven around the country. Selman said citation activity was "hardly anything" in New England and New York. The West Coast seems tougher than the East Coast, but the central part of the country has been hit hard.

Citations are often given for not having detailed enough plans, or not involving enough staff, she said.

"When CMS sent the guidance out, they said not to really expect to see surveyors getting tough for a period of 11⁄2 or two years out," Selman said. "We are just about entering that period."