Home Health & Hospice Week

But education can’t happen overnight.

You can’t have survey consistency unless surveyors are trained accordingly. So say many commenters on the home health proposed rule for 2022, which contains a number of significant hospice survey changes.

“Disparate deficiency citations between [Accrediting Organization] surveyors and [State Survey Agency] surveyors may, in part, be attributed to differences in surveyor training and education,” the Centers for Medicare & Medicaid Services notes in the proposed rule. “This variation may be due to inconsistencies in AO training with the CMS-provided SA basic surveyor training.”

To address this problem, CMS suggests “uniform surveyor training,” which would “increase the consistency between the results of the surveys performed by SAs and AOs, and have a positive impact on the high disparity rates,” according to the rule.

The Consolidated Appropriations Act of 2021 enacted last December requires the Department of Health and Human Services “to provide training for State and Federal surveyors, and any surveyor employed by an AO, including a training and testing program approved by [HHS], no later than October 1, 2021. Further, no surveyor can conduct hospice program surveys until they complete training and testing,” CMS notes in the proposed rule. (See story, p. 320, about survey change deadlines.)

Hospices are generally happy to see this additional training, according to their comment letters on the proposed rule.

“Proper training will not only benefit the surveyors in their work but has the potential to improve the survey process as well — particularly in the interpretation of regulations, expectations around documentation, and accessing employee records,” says the National Hospice and Palliative Care Organization in its comment letter.

Many commenters want to see such training fully implemented before other punishing provisions, like the Special Focus Program and enforcement remedies, go into effect. “Given the obvious inconsistencies among surveyors, we strongly believe that CMS should not put the cart before the horse in creating remedies/sanctions for noncompliance when the survey process has not yet been fixed,” NHPCO says.

“It would be optimal for all surveyors to undergo training and testing using the updated modules as soon as they are available,” says the National Coalition for Hospice and Palliative Care in its comment letter. “Rather than having AO surveyors undergo currently available surveyor basic training that may be out of date, we recommend that CMS publish, as part of its final rule … information regarding when the updated training modules will be released along with a schedule for when all surveyors must complete the revised training (and undergo competency testing),” the coalition suggests.

More time: “The schedule should allow sufficient time so that survey entities will not be required to remove a significant number of surveyors from the field at the same time so that the impact on survey backlogs will be minimal,” the coalition says.

“CHAP recommends that CMS provide six (6) months for the initial timing for AO surveyor compliance to avoid survey timing disruption,” the AO says in its letter.

The Texas Association for Home Care & Hospice, the Accreditation Commission for Health Care, and others recommend a minimum of three months.

Plus: “Survey entities would benefit from receiving information about how their surveyors have performed on CMS’ training modules. TAHC&H encourages sharing the details of the surveyors’ performance on the various testing modules so that the employing survey entity has knowledge of a surveyor’s knowledge base and areas of strength and weakness,” TAHC&H’s Rachel Hammon says in its letter.