Ask the payment expert ... about the observation stay loophole

How should our facility prepare for the new survey process?

The new skilled nursing facility survey process combines pieces of the traditional survey and some from the quality indicator survey (QIS). 

The new process puts more decision-making in the surveyor’s hands. For those still in the traditional survey process, this new process will be quite a change. It will be computer-based and depends somewhat on data that you submit through the MDS process. That will include quality indicators, as well as specific MDS sections.

You will, however, be going back to the use of the resident roster process with CMS 802 having to be completed for all residents admitted within the last 30 days. The new process also incorporates the new Requirements of Participation and the new F-Tags. 

The sample size for surveys will be dependent on the facility census, with about 20% sampled and at a maximum of 35 residents. Some sampling will still be computer-selected. Residents will be interviewed, observed and have limited record review.

It is expected that the first eight hours of the surveyor’s time onsite will be spent on this process. Surveyors will not have a set interview process. Investigation of problem areas will include usage of critical element pathways.

Mandatory tasks will be included for review just as they are now. The bottom line is, this process will be a bit difficult to begin with. The documents surveyors will use were still in draft form as of press time and some (CE pathways) have not yet been published. 

My suggestion is to read as much as you can about this process, attend educational programs offered by your state association and use the QIS tools that are presently available, including the interview guides and CE pathways. 

Those tools are at