Initial Pool: The First Stage of the CMS’s New Survey Process

The “Initial Pool Process” (IPP) forms the first major component of the Centers for Medicare & Medicaid Services (CMS) new survey process, which was instituted on November 28, 2017.

The IPP must be carried out on the first day of the survey, and will see the surveyors screening residents and helping to identify their resident sample pool—but only after first thoroughly going through the Certification and Survey Provider Enhanced Reports (CASPER) documentation relevant to that facility. This will ensure that all patterns of repeat deficiencies and other facility history information are identified. In addition, off-site preparation must include a review of selected residents, their indicators, and facility rates. The maximum sample size is 35 residents.

The process will be fully automated, and each survey team member will use a tablet throughout the survey process to record findings that are synthesized and organized by new software. At least 70 percent of the interviewees must be pre-selected, so that when the surveyors walk into the building, they will have to confirm that these pre-selected individuals are residents that should be included in the sample. The remaining 30 percent must be selected onsite and must include new admissions, vulnerable residents, and other residents with quality of life and care concerns.

According to CMS, the first eight to ten hours onsite will primarily be spent completing the initial pool process. This will entail the screening of all residents in the facility and narrowing them down to an initial pool of about eight residents per surveyor. Surveyors will then use the survey software to complete an observation, an interview (if appropriate), and a limited record review to help the team identify residents from the initial pool who should be in the sample.

Each surveyor’s initial pool will include some residents who have been pre-selected offsite based on Minimum Data Set (MDS) clinical assessments. Complaint or facility-reported incident (FRI) residents also may be identified offsite, and up to five (across the survey team) may be included in the initial pool. Surveyors indicate concerns for further investigation as they complete these activities.

The questions to be asked have been specified by the CMS, and must deal with topics such as what choices residents have with regard to their daily life, any activities they partake in, and other issues revolving around dignity, abuse, resident-to-resident interaction, privacy, the accommodation of physical needs, the handling of personal funds and property, staffing levels, all medical issues, and the perennial topic of smoking.

The surveyors will also ask for meal and medication administration times, the storage location of medication carts, access to electronic health records, and, finally, the updated facility matrix.
All of this will be needed to move on to the second component of the new survey process: the Sample Selection.