The Survey Data Is Clear. August Is the Riskiest Month.

Good morning,

This week I presented at a CCRC in Maryland about the current survey environment and how operators can use publicly available survey data to better prepare their teams and communities.

One important point that came up during the presentation is that this information is not only valuable for skilled nursing operators.

Assisted living leaders, independent living leaders, memory care leaders, and CCRCs should all be paying attention to these trends too.

Risk is risk.

The regulatory language may change depending on the setting. The enforcement process may look different. The citation pathways may not be identical. But serious operational failures almost always create serious regulatory consequences regardless of the line of business.

If your community has a code status failure, an elopement, a delayed emergency response, or a major supervision breakdown, you are at high risk for negative enforcement action whether you operate skilled nursing, assisted living, memory care, or a continuing care retirement community.

The regulators may call it something different. Families, attorneys, hospitals, and the media usually do not.

Honestly, I think understanding the survey environment is one of the most underused things administrators and executive directors can do.

There is a huge amount of information available if you know where to look. Deficiency trends, complaint investigations, Immediate Jeopardies, follow-up surveys, enforcement actions. When you spend time reviewing that information consistently, patterns start showing up very quickly.

One thing that stood out in Maryland was timing.

When you look at serious deficiencies over the last three years, most G-level citations and Immediate Jeopardies were issued during August.

That matters because many of the incidents leading to those surveys are happening right now.

The July and August follow-up surveys often come from self-reported incidents, elopements, injuries, abuse allegations, or serious accidents that occurred weeks or months earlier.

You cannot prevent every incident. But you can identify where surveyors are focusing and where communities continue getting into trouble.

Elopements continue to be one of the biggest drivers of serious deficiencies. Many of the Immediate Jeopardies we reviewed tied back to elopements and supervision failures.

Another trend that has become very clear is code status related deficiencies.

If staff do not know how to quickly identify a resident’s code status, if processes vary between departments, or if there is confusion during an emergency response, the likelihood of a serious citation goes way up.

The data shows these situations rarely end in low-level deficiencies. They are becoming Gs, Hs, and Immediate Jeopardies.

That means communities need very tight processes around emergency response and code status management.

Leadership teams should be asking questions like:

1. What is the single source of truth for a resident’s code status?
2. Can every nurse and caregiver identify that source immediately without hesitation?
3. Are there multiple places throughout the community where code status information exists and could conflict?
4. When was the last time you ran a code drill?
5. What went wrong during that drill?
6. What changes were made afterward through your QAPI process?

These are the situations surveyors are looking at closely right now.

And the communities that perform best during survey are usually the ones paying attention to these trends before surveyors walk through the door.

We are also going to start doing something new to help operators stay ahead of these issues.

Beginning next Thursday, we’ll host a free weekly lunchtime survey huddle at 12:30 PM on Google Meet.

Each week we will review a real serious deficiency from somewhere in the country that was cited within the last six months. We’ll walk through what happened, what broke down operationally, what warning signs were missed, and what communities should be doing today to reduce the risk of the same thing happening in their building.

Short, practical, and focused. Something you can take back to your team immediately.

Have a great day,

-Kevin

Whenever you're ready, I can help you in a few ways.

1. Use our free AI-powered Chatbot trained on all 900 pages of CMS Nursing Home Regulations, proprietary processes, and information from decades of skilled nursing leadership experience.  Click here.
2. Sign up for Assisto and keep track of the regulatory environment in your state.  Know what deficiencies surveyors cite in real-time and ensure you're not at risk for the same tag.  Sign up here.
3. Take our Salary Lens survey and gain access to the largest database of senior living and SNF leadership salaries in the industry.  Check it out here.

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Kevin Goedeke, Publisher and Founder