Ensuring a Smooth Survey: Why the Surveyor's Contact Should be a Clerical Person
The first, and perhaps most important, thing you can do for your survey prep is to designate the primary contact for the surveyor. This is the most overlooked part of survey preparation but choosing the right person can make or break your experience. Most home health and hospice agencies, faced with this question when the surveyor walks in and asks for it, naturally designate the Administrator, Director of Patient Care Services or Nursing Supervisor. It’s been our experience however, that assigning a clerical person is the best use of your resources. Here’s why:
The primary contact person is the “Surveyor’s Buddy”
They are expected to spend a lot of time with the surveyor, time that they can spend doing other things. When this person is the clinical office person, the opportunity cost of spending that time with the surveyor fetching charts and other paperwork could be spent doing chart reviews, selecting the patients to be visited and directing field staff. Instead of assigning the Director of Nursing or the Nursing Supervisor, delegate the task to the person responsible for payroll, or another set of tasks that don’t necessarily need to be urgently addressed.
The surveyor will ask their buddy process and policy questions
When the main contact person for the survey is the home health or hospice agency’s Administrator, DON or Supervisor, they are expected to know the answer. Even If this person doesn’t know the answer, they are expected to know how to retrieve it. Not knowing at least how to reference the information being asked essentially leads to a deficiency. The clerical survey assistant is not expected to know all the home health/hospice rules and regulations, or the agency’s policies. It’s not surprising or disappointing then, if the clerical survey contact needs to check with upper management or the policies book. This ensures that all your answers align with the actual policies.
When a surveyor finds a deficiency they ask the survey contact to confirm what they are seeing
In these instances the non-managerial survey contact can ask to bring higher level personnel to assist in this process. This gives agencies an additional few minutes to think about what’s being asked, what deficiency is being pinpointed and to come up with a well thought out response instead of a panicked one on the spot. If the question is about missing wording in a policy, not-submitted documentation or anything else that’s easily correctable, the support staff working on chart reviews can contact the appropriate personnel and get the missing information while the management level person is communicating with the surveyor. Sometimes a few extra minutes are the difference of a deficiency.
The survey contact person will also end up accompanying the surveyor to patient home visits
Here, the surveyor observes the field staff interact with the patient and makes sure that the field staff is following important infection control procedures and the plan of care. If the field staff makes a mistake, the surveyor can start questioning the Director of Nursing or Nursing Supervisor on the spot regarding policies, competencies and other information. A clerical person is unlikely to get this level of questioning and can usually warn the office about finding so that the appropriate personnel can prepare how they can answer questions that may come up afterwards. Besides the preparatory factor, agencies don’t need their main clinical staff out of the office for hours, prime time for chart reviews and other activities.
The most difficult part of a survey is the theme of surprise that lasts throughout the entire process. Agencies are surprised when the surveyor comes in, and they normally can’t anticipate the issues that are unearthed. Many tracer activities lead to “on the spot” questions that lead to hurried answers. The best thing you can do to ensure the success of your survey is to minimize the element of surprise as much as possible. This allows for careful consideration and thought out answers that can be the difference of a long or short plan of corrections, which we can discuss at a later post.