Everyone can remember that teacher. That really tough one.
The one who made you work for your grade. Intimidated you, especially if you hadn’t done your homework, for whatever self-inflicted reason.
He or she also was probably the one who gave you exhaustive study lists and review sheets before the big tests. Might have even given you chances to earn extra credit to lift your grade. But you had to work for that, too.
This describes exactly what nursing home operators are facing from their toughest “grader” in this anxious pandemic era.
With infection control matters under all-time high scrutiny thanks to COVID-19 conditions, the Centers for Medicare & Medicaid Services has raised the stakes on surveys. Namely, they recently suspended all normal survey activity to focus exclusively on infection control practices (as well as Immediate Jeopardy conditions.)
To help providers get ready for the extra scrutiny, the agency distributed a memo, with a detailed voluntary self-survey within, the “COVID-19 Focused Survey for Nursing Homes.” Or as you might have called it in high school, the pretest packet. Use it at your own discretion, ignore it at your own peril.
As one expert recently put it, it’s voluntary, but ridiculous to ponder: Why not take advantage of it? It uses the same pathways surveyors will use.
Or to put it another way, it’s like getting the answers to the test ahead of time — in a legal and ethical manner.
In fact, CMS and Centers for Disease Control and Prevention officials put on their “teacher’s robes” and state outright that the memo and self-survey were developed “so facilities can educate themselves on the latest practices and expectations.” Furthermore, they expect facilities to use them to perform the voluntary self-assessment because the document may be requested by surveyors, if an onsite investigation takes place.
The nine-page checklist will take some time to complete. But the issues will be no surprise: hand hygiene, general standard precautions, procedures and policies, emergency preparedness and so on. The better shape you’re in, the quicker your completion of this pretest will go. By the same token, the slower it goes, the quicker you know what you need to improve.
And make no mistake, if it goes slowly, you are more than likely to be quickly strung up by surveyors. They’ll be intent on heading off the next viral outbreak. And after that, who knows what you’ll face. Perhaps an irate public, litigious-minded family members or fist-pounding accreditors.
Surveyors will be coming in with a focused set of criteria — essentially the one you have had at your disposal for several weeks now. Rest assured it will be used for many months, even after this initial COVID-19 tidal wave of fear and stop-gap measures flows past.
Any excuses for not taking advantage of the focused survey document now, and aggressively so, just don’t stack up against the potential consequences of not doing so.
Besides, as one industry veteran who has been on both sides of the surveyor’s clipboard puts it, there’s no sense irritating a surveyor. Especially if he or she has given you the answers to the big test before ever entering the door to administer it.
Follow Executive Editor James M. Berklan @JimBerklan.
