Nursing homes across the country are still being hit with frequent Focused Infection Control surveys, nine months after the Centers for Medicare & Medicaid Services announced that surveyors should begin emphasizing standard inspections again “as soon as resources are available.”
According to one analysis, more than 81% of infection control surveys reported between April 2020 and April 2021 resulted in no citations.
Still, nationwide, CMS reported an average of four such inspections per-facility. The agency’s data shows a wide variation in regularity of those site visits, from 1.49 per year in Vermont to an annual average of 12.18 in Connecticut.
And when providers are dinged for infection-related deficiencies, they are facing stiffer penalties than they do on typical surveys, said Spencer Blackman, director of product for StarPro, which provides data insights to operators, lenders and insurers.
The average points-per-deficiency for the last year’s worth of infection control surveys was 12.63, compared to 11.68 for complaint-driven surveys and 7.09 for standard surveys, according to StarPro’s analysis of CMS data. Those points influence providers’ star ratings, which are also becoming more outdated the longer it takes for standard surveys to rebuild in volume.
“At this point, it really seems like CMS should be putting the spurs to the SSA (state survey agencies) to pick up that activity again because the lag, how old these surveys are, is getting really dramatic,” Blackman told McKnight’s. “That’s not good for the homes because they’re stuck with a bad survey, and it’s not good for the public because they’re not getting the most current information available.”
Janine Finck-Boyle, vice president of regulatory affairs for LeadingAge, said Friday that a revision to CMS guidance issued in January prolonged the use of infection control surveys when facilities report a high proportion of new COVID-19 cases, issues with outbreak testing or low staffing levels.
“Although cases are declining as vaccination percentages increase, there still are cases,” Finck-Boyle said. “And so what I think CMS has instructed states to do is to make sure nursing homes are still focusing on their infection control programs, that they have good hand hygiene, that they have PPE, that they’re donning and doffing.”
Pleading the one-fifth
Like complaint-driven surveys, infection control surveys fall down in the ratings calculation after one year. So even a clean survey can’t necessarily counter a facility’s poor showing on a standard survey pre-COVID-19. Standard surveys are calculated in ratings over three years, meaning some providers are still grappling with negative findings from 2019
In a typical year, Blackman’s firm expects to see between 1,250 and 1,300 standard surveys conducted monthly. For February, March, and April, 2021, CMS reported surveyors conducted about one-fifth that rate: 230, 216 and 335, respectively, nationwide.
Among the few hundred annual surveys for licensure and complaint-driven surveys, the F-880 tag for infection control deficiencies remains among the Top 5 most frequent. Providers could be docked with the tag for non-compliance with hand hygiene standards, PPE or failure to adequately screen incoming staff or visitors.
In many cases, LeadingAge members continue to report that focused infection control surveys remain largely cooperative, with surveyors offering resources and making suggestions that would improve resident and staff safety.
“We really saw there was a collaboration,” Finck-Boyle said. “I wouldn’t say surveyors were missing any deficiencies.”
In fact, Finck-Boyle said the higher points-per-deficiency likely indicates tags are being given when surveyors identify patterns or widespread failures related to a breakdown in infection control programs.
“It’s a thread (running through) the system,” Finck-Boyle said. “It’s not just one incident.”
For citation information reported for April 2021, long-term management and consultant firm Pathway Health found F-880 continues to dominate nationally. That was followed by:
F-884 — Reporting – National Health Safety Network
F-689 — Free of Accident Hazards/Supervision/Devices
F-684 — Quality of Care
F-686 —Treatment/Svcs to Prevent/Heal Pressure Ulcers
F-812 — Food Procurement, Store/Prepare/Server Sanitary
F-677 —ADL Care Provided for Dependent Residents
F-580 — Notify of Changes (Injury/Decline/Room, etc.)
F-656 — Develop/Implement Comprehensive Care Plan
F-609 — Reporting of Alleged Violations
F-761 — Label/Store Drugs and Biologicals
F-886 — COVID-19 Testing-Residents & Staff
Earlier this year, and again in April, Finck-Boyle reported that F-689, F-684 and F-812 were trending among the most common citations. She said that may be because those tags, also commonly cited deficiencies in pre-COVID days, act as a catch-all. Providers can be docked for a single violation or for more prevalent problems.
No matter what kind of surveys they face, Finck-Boyle said providers should be prepared to use them to inform future efforts. She suggests providers review past surveys and build performance improvement programs around prior weak spots, educate clinical and non-clinical staff, and test and mock survey all kinds of workers on key items.
“The only way to succeed is to be together on this,” Finck-Boyle said.
As Blackman notes, for providers uncertain how long they’ll have to wait for their next standard survey, doing well on one now becomes all the more critical.
“You don’t want to change drastically what homes should expect when these new standard surveys come in, but the main thing that we found is just that there are fewer of them,” Blackman said. “The stakes are high.”