In April 2024, the Centers for Medicare & Medicaid Services (CMS) announced the testing of a risk-based survey (RBS) that streamlines the standard recertification process for high-performing nursing homes. This appears to be a direct response to surveyor staffing shortages along with the absence of a budget increase to acquire the additional necessary staff.
The RBS will allow CMS to use data to “devote more time and resources to nursing homes with lower quality whose residents are at higher risk of harm.”
This shortened survey is still in the pilot phase, and little is known about the criteria by which nursing homes qualify for it. However, CMS indicates that a “history of fewer citations for noncompliance, higher staffing, fewer hospitalizations, and other characteristics (e.g., no citations related to resident harm or abuse, no pending investigations for residents at immediate jeopardy for serious harm, compliance with staffing and data submission requirements)” is considered. Up to 10% of nursing homes within a state may qualify for the RBS.
While we wait for additional data on the criteria, survey protocols, results of the pilot phase, and possible expansion, anecdotally, we have heard that the RBS is 50% shorter than the traditional survey and considers fewer residents. It still addresses all compliance and health/safety issues, and the pilot team of surveyors tries to follow the state survey team within a few days.
I’m encouraged. This is a purposely calculated first step to use data to focus limited resources. In December 2023, I wrote about how survey delays are really hurting our industry. Some providers thought I was crazy, but most understood how the lack of contemporary data is often injurious to them in the eyes of the public, including consumers, referral sources, lenders and many others.
Consider this: For almost 60% of nursing homes, their Five-Star Health Inspection rating is equal to their Five-Star Overall rating. The survey process is the tail wagging the Five-Star dog. For providers who are diligently working on quality improvement efforts and on staff recruitment and retention, the opportunity to demonstrate their success to the community shouldn’t be hampered by surveyor staffing shortages that delay updates to their Health Inspection rating.
The average “Cycle Three” look-back is about five years, and this varies widely by state. Should a five-year-old report card really be informing residents, consumers and the general public about nursing home quality?
Steven Littlehale is a gerontological clinical nurse specialist and chief innovation officer at Zimmet Healthcare Services Group.
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