Good morning.
CMS Just Turned Survey Readiness Into a Public Scoreboard
CMS just made a pretty significant change to the nursing home survey process.
And I don’t think the biggest story is that some facilities may get a shorter survey.
Beginning September 8, CMS started implementing its new Risk-Based Survey process nationwide. Roughly 12% of nursing homes are expected to qualify. Those facilities can receive a more focused recertification survey with fewer surveyors, fewer activities, a smaller resident sample, and roughly half the onsite time of the traditional process. CMS also plans to publicly identify qualifying facilities on Care Compare with a high-performing facility icon beginning with the September refresh. (Centers for Medicare & Medicaid Services)
That is interesting.
But here’s the part I think operators should really pay attention to:
CMS basically just published an 11-point definition of what it believes a lower-risk, higher-performing nursing home looks like.
And it is a much better operating checklist than “How many stars do we have?”
To qualify, a facility cannot have any of 11 disqualifying conditions.
Some are obvious:
- Less than a 5-star overall rating
- Less than a 3-star staffing rating
- An Actual Harm, Immediate Jeopardy, or Substandard Quality of Care citation during the last survey cycle
But keep going.
A failed PBJ staffing audit knocks you out.
A failed MDS audit knocks you out.
A health inspection score worse than the median in your state knocks you out.
Certain schizophrenia coding patterns knock you out.
A staffing waiver knocks you out.
A recent change of ownership knocks you out.
Special Focus Facility candidate status knocks you out. (Centers for Medicare & Medicaid Services)
Look at that list again.
That isn’t one department.
That’s operations.
Clinical. Staffing. MDS. Compliance. Data integrity. Ownership. Survey history.
All touching the same outcome.
That is the lesson I would take from this even if I had absolutely no interest in earning a trophy icon on Care Compare.
Too many buildings still manage performance in departments.
Nursing owns clinical.
HR owns staffing.
MDS owns MDS.
The administrator owns survey.
Somebody in corporate owns PBJ.
And then we act surprised when the problems connect themselves before we do.
They always connect.
A scheduling problem becomes a staffing-star problem.
A staffing problem becomes a care problem.
A care problem becomes a complaint.
A complaint becomes an investigation.
A weak investigation becomes a citation.
And suddenly five things that lived on five different spreadsheets are now one very expensive problem.
CMS is essentially saying the same thing with this new model:
High performance is not one great metric. It is the absence of major weaknesses across multiple systems.
And there’s another important wrinkle.
Even after a facility makes the qualified list, it can lose eligibility before the survey begins. New Actual Harm, IJ, abuse or SQC findings can do it. So can a pending IJ investigation, more than three pending non-IJ active complaints or facility-reported incidents triaged at medium or higher, a nursing waiver, or a change in ownership. If one of those occurs, the state must convert the RBS back to the traditional survey process. (Centers for Medicare & Medicaid Services)
So no, this is not a reason to relax because you made the list.
Quite the opposite.
It is another reminder that real survey readiness is an operating system, not an event.
5-Minute Building Audit
Pull up CMS’s 11 RBS qualification criteria.
For every item, answer two questions:
- Who owns this in our building?
- Where would I look today to know whether we are okay?
If you cannot answer both in about five seconds, that is probably worth fixing.
Not because CMS has a trophy waiting for you.
Because if nobody owns the signal and nobody knows where to see it, you usually find out there is a problem later than you should.
One Number
12%.
That is approximately how many nursing homes CMS expects to qualify initially. (Centers for Medicare & Medicaid Services)
My goal wouldn’t be to chase the 12%.
My goal would be to build the kind of operation where the 11 things CMS is looking at are already things we are looking at.
The trophy should be the byproduct.
The operation is the point.
— Kevin | 