The New Survey Process: What is it, and Why?

November 28, 2017 was the Centers for Medicare & Medicaid Services’ (CMS) deadline for implementing the “new survey process”—but the good news is that the authorities have granted a grace period of 12 months during which there will be no penalties for certain selected F-Tags in order to give all long-term care facilities (LTCs) the time to fully convert to the new system.

The obvious question which commonly arises is why is the CMS new survey process being implemented at all?

The simple answer is that it has been designed to establish a computer-based, nationwide survey process to ensure patient/resident well-being and quality of care.

As readers will know, nursing home surveys are conducted in accordance with protocols and federal requirements to determine eligibility for participation in the CMS’s ongoing programs. However, a lack of a uniform standard in conducting this survey has produced its own set of problems.

Currently, about half of all LTCs use the Quality Indicator Survey (QIS), and the other half use the traditional survey process, according to CMS data.

While the traditional processes have both positive and negative attributes, the reality is that the survey systems have not been updated in nearly a quarter of a century—and the time for such an update is well overdue, given the advances in administrative processes and technology, the CMS has said.

The QIS system, while computer-based, can seem too regimented or inflexible, while the traditional process allows the surveyor “a little more flexibility,” a recent CMS handout on the process said, adding that the new survey process “leverages best practices of both.” In other words, it will be completely computer-based, but incorporate the flexibility of the traditional paper process.

The computer-based QIS proved to be better at identifying unnecessary medications, while traditional, paper-based surveys proved better at identifying infection control issues, the CMS said.

The new process will be split into two parts: a resident sample selection, comprised of 70 percent of residents chosen offsite and 30 percent selected onsite, followed by an investigation.

The launch of the new process will also mean changes to the F-Tag system, with some tags splitting into more than one tag, others being combined, and some being completely new.

Coming on top of QAPI and a host of other administrative changes, CMS has acknowledged that forcing all LTCs to immediately comply with the CMS new survey process might cause internal problems.

On November 24, 2017, therefore, the CMS announced that following the implementation of the new LTC survey process on November 28, 2017, they would hold constant the current health inspection star ratings on the Nursing Home Compare (NHC) website for any surveys occurring between November 28, 2017 and November 27, 2018, thus effectively giving facilities twelve extra months under the CMS new survey process before their results become public.