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Collaborate or Punish: Is There a Middle Ground to Be Found in the Survey Process?

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March 05, 2021

ilene warner-maron, phdThe COVID-19 pandemic has substantially altered the practice of long-term care delivery, including the methods used to assess the quality-of-care.  CMS has focused the survey process specifically on the infection control practices of facilities, and it has caused some to question if the manner in which inspections are performed will evolve into a more collaborative effort.

In a recent statement during a LeadingAge call for members, Evan Shulman, the director of the Division of Nursing Homes for CMS, said the likelihood of moving away from a punitive approach to surveying to a more collaborative approach seems remote. Mr Shulman noted that both surveyors and facilities collaborated on best practices to mitigate COVID-19 as the virus and its impact were uncharted waters. As the cases of COVID-19 in long-term care facilities declines as a consequence of vaccination and decreased infections in the surrounding communities, a return to the regular survey process is likely. 

Mr. Shulman stated, “We do not support collaborate surveys and here’s why: The foundation of oversight depends on accountability from a regulator and the people that it regulates. That needs to be objective.”

An objective approach to the inspection of long-term care facilities would be an obvious goal, however the current process may not be objective as there is evidence of great variability within states as well as between states. If collaboration is not the goal in the survey process, finding ways to maximize the objective quality-of-care and quality-of-life measures in a nursing home would be appropriate. The punitive aspects related to deficient practices are required as negative incentives, however the balance between subjective observations and objective observations during the survey process is necessary as is the goal of ensuring that we are actually measuring the provision of care which is meaningful for the resident. 

Facilities can and should identify the most important aspects of care during the QAPI process and use this opportunity to determine methods to improve the provision of care regardless of when surveys are due. Long-term care has traditionally responded with improvements and innovation after citations have been identified. 

Can we use COVD-19 lessons to improve our care proactively, rather than in response to the survey process?

Ilene Warner-Maron, PhD, RN-BC, CWCN, CALA, NHA, FCPP, is an assistant professor in the Department of Geriatrics and Palliative Medicine at the Philadelphia College of Osteopathic Medicine. Dr Warner-Maron is also the executive director of the Eastern Pennsylvania Geriatric Society. 

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