Home Health & Hospice Week

Survey & Certification:

TREAT QIOs AS SURVEYORS

Despite potential regulatory problems a relationship with a Quality Improvement Organization might involve, home health agencies shouldn't necessarily rule out working with QIOs altogether.

No matter what, those 11 patient outcomes the Centers for Medicare & Medicaid Services has chosen are going to show up in local newspapers, on CMS' Home Health Compare Web site and in other locations. Working with QIOs can help agencies improve those outcomes and, of course, actually improve patient care.

That, in turn, could boost referrals and keep surveyors, who rely on OBQI reports to organize their investigations, at bay.

HHAs that choose to go to QIOs for help should be smart about it. Treat any information you share as if it will definitely cross a surveyor's desk, advises attorney Deborah Randall with Arent Fox Kintner Plotkin & Kahn in Washington.

Document interactions with QIOs as carefully as interactions with surveyors, counsels attorney Virginia Caudill with Indianapolis-based Gilliland & Caudill. That means painstakingly recording all materials you give to them and having multiple people from your organization in on any meetings, just like with survey exit interviews.

If QIOs want to speak with patients, be sure to accompany them, Caudill adds.

Proceed cautiously, be leery and use good judgment and common sense, they advise. "Go with your gut instinct," Caudill suggests.

Editor's Note: The document on QIO roles is at www.cms.hhs.gov/quality/hhqi/default.asp.