This past spring, the Centers for Medicare and Medicaid Services (CMS) resumed full survey activities, so you can be sure they will be out in your area soon. What should you expect from the survey process, and how should you prepare? In this blog we have simplified these complicated questions for you, so you can be ready for the CMS surveys coming soon to an office near you.

CMS Surveys: The Process

State Agencies (SAs) use qualified health professionals to conduct field audits, called “surveys,” of Medicare or Medicaid-certified agencies. These on-site visits are used to determine whether and how the CMS requirements are met. Home health agencies cannot bill for services provided to Medicare or Medicaid beneficiaries unless they meet every Condition of Participation (CoP) standard.

These federal CMS requirements are often identical to state statutes but sometimes differ. That is why agency operators need to be familiar with both sets of rules when talking with the surveyors.

The State Agency (SA) visits the home health company to survey its operations. They gather information to determine compliance in three primary ways:

• Interviews with staff and patients
• Medical Record/chart reviews
• Home visits

Following the SA surveyor’s inspection, they will document their findings. Read more about what happens when the state finds deficiencies in Alora’s blog on survey preparation.

When an agency fails to meet the minimal standards of their certification with CMS, the SA prepares a certification form for the CMS Regional Office. This form, CMS-1572) Home Health Agency Survey and Deficiencies Report – OMB 0938-0355, is a formal Statement of Deficiencies.

CMS gives agencies ten calendar days to respond with a Plan of Correction (POC) for each cited deficiency.

In addition, some deficiencies carry sanctions. Directed education, interim management by CMS, suspension of payments, and monetary penalties are among those you do not want that responsibility. So how do you prepare?

CMS Surveys Preparation

There is a lot you can do to prepare for the survey. Many agencies conduct day-to-day operations with survey readiness in mind.

Incorporating compliance into everyday functions is easier and much more effective than implementing short-term survey preparation plans.

Creating a culture of compliance by educating staff on requirements and holding them accountable goes a long way in survey prep. Keeping records and data organized through a home health software system while implementing best practices for administrative and field staff can also go a long way towards keeping your agency prepared. If you’re already doing these things, you have a great foundation, but there is still more to do.

Review Database Reports

Home care providers should keep in mind that the survey begins before the auditor arrives on your doorstep. Before the on-site visit, SA employees analyze information in the federal database to know what areas of compliance to check on. Documentation that is viewed before your survey visit includes:

• Previous survey findings and plans of correction
• State complaint history
• Certification and Survey Provider Enhanced Reports (CASPER)
• OASIS submission data

Since you know they will be looking at these, you should too. Identify any areas of concern. Use these for quality improvement projects and staff education. Then document your efforts.

Prepare for the Top Deficiencies

CMS publishes an updated list of current deficiencies. This invaluable tool allows agencies to see what surveyors need to see.

Out of 449 deficiencies listed in 2021, here are the top-cited deficiency descriptions included:

• Plan of Care – 62 deficiencies cited
• Promptly alert the relevant physician of changes – 25 deficiencies cited
• Infection control and prevention – 23 deficiencies cited
• Following physician orders – 19 deficiencies cited
• Provided services in the Plan of Care – 18 deficiencies cited
• Document complaint and resolution – 12 deficiencies cited

Using this information, agencies can prioritize areas for survey preparation.

Get Familiar with the Interpretive Guidelines

In addition to knowing “the regs” and current trends in survey deficiencies, agencies should get familiar with the Home Health Interpretive Guidelines. This CMS document provides agencies with clarification, definitions, and more information.

Take the top three or five areas that your agency will focus on for survey readiness and review the guidance to improve compliance.

Summary

Using available data and reports, agencies can develop and implement plans to improve compliance and be ready for the next survey. Survey readiness can be a complicated task, but it doesn’t have to be. Now that you know what the survey process looks like and how to prepare, you can get to work. And be ready for the CMS survey, coming soon to an office near you.

If you found this helpful, be sure to share this resource with your team.

Author’s Note: Views, information, and guidance in this resource are intended for information only. We are not rendering legal, financial, accounting, medical, or other professional advice. Alora disclaims any liability to any third party and cannot make any guarantee related to the content.