Knock, Knock!
What to Do When the
Surveyor Shows Up
America’s Choice in Homecare Pat Drea:
Chief Operations Officer Visiting Angels
PARIVATE DUTY HOME CARE
LEADERSHIP SUMMIT
January 18 – 20, 2009
State Licensure Regulations
More states are becoming licensed
28 states & more pending
Regulations offer:
Consumer protection
Screening of new businesses
Ongoing quality control
Regulatory oversight is here to stay
1
Each State Is Unique
Content has been drawn from experience many
licensed states
Each state has unique regulations and methods of
enforcement
Adopt these ideas to your specific state.
Some states include . . . But not limited to
Alaska Connecticut Colorado Delaware
Florida Georgia Illinois Indiana
y
Louisiana Maine Maryland
Massachusetts Minnesota Nebraska
Nevada New Hampshire New Jersey
New York North Carolina South Carolina Oregon
y
Oklahoma Pennsylvania Rhode Island
Texas Tennessee Utah Virginia Washington
Be sure to check with your state’s website!
If your state does not have a home care specific license now …
they are likely to in the coming months or years.
2
What Does Licensure Require of Me?
Initial application process & fee
Initial survey
Compliance on an ongoing basis
Occasional routine surveyor visits
Surveyor visits for complaint investigation
Stay up to date on changes in the regulations or
interpretation of regulations
Renewal of license every 1 or 2 years
Annual Data Report submission - clients & caregivers
Common Requirements
Policies and Procedures
g
Service Agreements
Bill of Rights
State agency complaint hotline (listed on
admission information)
Assessment and Care Plan requirements
g y
Administrator for agency
Liability insurance
Acceptable credentials (CNA) for hands on care
Background checks
3
More Requirements
Document hours that were not staffed
p
Complaint records & tracking g
Reporting of CNAs to Aide Registry for theft,
etc.
Record retention and security
Contents of client and caregiver records
On site supervision of cases
RN assessments and supervision
Advance written notification of discharge
List contact info for other agencies
Specific Policy Requirements
Admission
Annual Review & Quality Assurance
A lR i Q lit A
Meetings
In-
Orientation & In-service
Complaints
S per ision
Supervision
Discharge Policy
. . . and more
4
State License Compliance Areas
Governing Body/Bylaws On Call Process
Administrator Qual. Infection control
Services Provided Emergency & Disaster
Personnel Policies – office File Management
& caregiver Complaint Management
Caregiver Qualifications Care Plan/Services Agree.
CNA verif of registrations Admission & Discharge
TB Testing Billing / Collection Policy
Job Descriptions Liability Coverage
Supervision Annual Data Submission
Caregiver Orientation
Be In The Know!
How to Stay in Compliance
State s
Know your State’s regulations – refer to them
often
Attend regulatory conferences held by your
oversight agency or home care association
Know the frequency of surveys
Stay in touch with other agencies in town and
other VA offices – find out results of their
surveys & what they learned
5
Implementation Strategies
Create implementation tools – reference
materials on regulations and clarifications
Use an implementation spreadsheet (next
slide)
p policies & forms
Prepare and date drafts of p
Meet with team regularly
Use an action plan & document progress
Implementation Spreadsheet
equ e e t
Requirement Sect o
Section ct o te s
Action Items
Governing Body /Bylaws 355.30 policy
Liability Insurance 355.40 cert of insurance
Background Checks 355.71 policy
Complaint Resolution 355.50 policy
Administrator 355.51 policy/job descript.
Client Service Contract 355.90 policy /form
Care Plan 355.91 policy/form
Quality Improvement 355.95 policy/satisfaction
survey forms
6
Like a Boy Scout:
Be Prepared!
Richard 1964
Educate office staff on requirements
Use checklists for compliance (client and
caregiver file contents, supervision,
documentation, etc)
Audit compliance monthly or quarterly
Streamline your processes so you comply
up front – ex. Orientation
Systems that Do the Work for You
1. Log changes in hours and schedules daily
2.
2 Scheduling system up to date
3. Document conversations with clients, families
and caregivers
4. Document and follow up on complaints
according to requirements
5. Use software to schedule supervisory visits, TBs,
Inservices and other requirements Tip: schedule
TB 1 mo earlier than due to be timely
6. Stay up to date with filing
7
Attitude is Everything!
Convey the attitude that compliance is
important
Office staff will follow your lead
Manage proactively – audits will keep you
in compliance
Praise staff for consistent compliance
Knock, Knock
Your surveyor has arrived!
Don’t panic – Smile!
Don t
Invite her in, exchange business cards, (This
avoids scams)
Offer a private place for her to work –
(private room preferable, away from phone)
Off a b ff
Offer beverage: water, tea, coffee.
Offer lunch if appropriate or direct to a
lunch place nearby
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Typical Survey Visit
1. Opening Discussion – 30 min
eg.
What she will review, eg. Charts, policies & forms. Surveyors often
request caregi ers hich the
req est a list of clients & caregivers from which they select a sample
of active and discharged clients. Be sure you know how to print off a
list. - 30 minutes.
2. Audit Time – 2 hrs to 2 days
Record and policy review time. Be close by to respond to requests,
answer questions, provide additional material. (Cancel all
appointments.) 2 hours to 2 days
3. Exit Conference – 10 min to ½ hr
Summarizes findings, informally tells you citations, may comment on
strengths & weaknesses. Optional step.
Hints, Guidelines and Suggestions
1. Be gracious. Even if you disagree, do not argue!
2. Regulations - not a course in logic.
3. Okay to seek clarification & ask questions but
be polite. (occasional issues on Medicare vs.
regs)
Private Duty regs)
4. y
Clear your calendar for the duration of the visit.
If your staff are interviewed, stay in the room.
You are there to help guide the conversation.
5. Cooperate with requests.
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Hints, Guidelines and Suggestions
6. Use time to your advantage – most surveyors will
ll t l t i i it
allow you to locate a missing item.
7. Respond to questions but don’t offer extra
information.
8. 1 or 2 citations are not unusual. Take citations in
stride.
9 Your preparation and your attitude will have the
9.
greatest effect on the outcome. Be cooperative.
10. Know that recommendations will make you a
better agency.
Exit Conference
1. Surveyor will outline findings.
2.
2 If the surveyor identifies missing items that were
actually present, diplomatically point them out.
3. If you are unclear about a requirement, politely
request clarification. If there seems to be an error
(i.e. regs for certified agencies) ask if they would
check into this item but do not be confrontational.
4. Take notes on the conversation.
5. Ask when you will receive a written report.
6. Ask if there will be a follow up survey and when.
7. Thank the person for their time and assistance.
10
What To Do After the Survey
1. Immediately resolve items that you know you
for You’ll
will be cited for. You ll have a head start on
your corrective action report.
2. Incorporate process improvements that will
correct the root causes of problems.
3. Upon receipt of the letter, note the deadline &
start preparing the response.
p p g p
4. If you don’t receive the letter by the deadline,
call the office & inquire.
Preparing Your Written Response
typical-
Column form is typical- format your responses in the
proper column, tricky but effective.
Respond to each item individually even if the citation is
R dt h it i di id ll th it ti i
mentioned 10 X for 10 charts.
Your response should show
1. How you corrected this issue
2. When the correction was completed or will be
completed.
3. What you have done to prevent this problem in the
future.
Complete corrections within a reasonable timeframe
eg. 30 days not 6 months.
Ask for help if you need it.
Respond by the deadline - keep a copy for your files.
11
Compliance Tools
Caregiver check off list for a new caregiver
Client chart audit tool
Caregiver chart audit tool
Software system tracking for routine items:
Supervisory visits, TBs, inservice requirements: annual universal
precautions and HIPAA, annual caregiver evaluations
Complaint forms and logs
Check list for regulatory items
Note the date on your calendar for your license
renewal
Newly Licensed State
1. Review your draft regulations & attend educational
sessions
2. Make a list of policies, forms and application information
you’ll need
3. (eg.
Identify new processes (eg. Annual Review Meeting, RN
assessments on new cases)
4. Note the date for the submission of all materials, break it
up in chunks, then “back plan” to prepare for submission
5. Use the t t t d ft li i fi d f
U th extranet resources to draft policies & find forms
6. Pool the efforts of the franchisees in your state to prepare
materials
7. Create a mock survey
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CONGRATULATIONS!
You are fully prepared for a visit
from your surveyor
P D
America’s Choice in Homecare
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