Home Health & Hospice Week

If interviews of your staff are a wild card in your survey process, you could wind up with a losing hand at survey time.

In its new survey protocol that took effect in May, the Centers for Medicare & Medicaid Services directs surveyors to focus much more on home health agency staff interviews and less on non-clinical paper compliance, noted CMS's Pat Sevast at the National Association for Home Care & Hospice's annual meeting in Las Vegas.

And more interviews are exactly what HHAs in the field are seeing, relates consultant Pam Warmack with Clinic Connections in Ruston, La. "The surveys that have been occurring in the last three months of this year have certainly reflected the change in the survey approach under the new protocols,"  Warmack tells Eli. "Surveyors have been interviewing staff left and right. They have even gone so far as to call staff members on the phone to interview them."

Agencies that have been accredited by the Joint Commission (formerly JCAHO) are more used to this process, finds Chicago-based consultant Rebecca Friedman Zuber. The Joint Commission "has been using these techniques for many years."

"The process of randomly 'talking' (and walking around) with different members of the home health agency is something I did as a JCAHO surveyor since 1993," points out consultant Lynda Laff with Laff & Associates in Hilton Head Island, S.C. "A seemingly innocent conversation in the ladies' room or office kitchen can yield great insight into how the agency really works -- off script," Laff warns.

Use these expert tips to prepare staff for surveyor interviews and protect yourself against deficiency citations:

1. Practice, practice, practice. Practice may not make perfect when it comes to staff interviews, but it at least will increase your chances of having a good survey. "Conduct your own internal mock surveys and interview everyone," Warmack urges. Remember that surveyors can interview nonclinical staff, such as the receptionist, Sevast said to attendees of her standing-room-only Oct. 3 session.

Conducting staff interviews "has been an eye-opener" for many providers, Warmack says.

"There is no substitute for practice when it comes to responding to surveyors," believes Washington, D.C.-based attorney Elizabeth Hogue.

2. Study Appendix B. Revised Appendix B is in effect, even if it's not officially posted to the State Operations Manual website yet, Sevast emphasized (see related story, p. 288). That's where you need to draw your interview questions from, Warmack advises. "When you read Appendix B, it is easy to identify the questions that surveyors will be asking," she maintains.

Tool: Revised Appendix B is in Survey & Certification letter S&C: 11-11-HHA available at www.cms.gov/Surveycertificationgeninfo/downloads/SCLetter11_11.pdf.

3. Hit the road for interviews. Zuber recommends "having supervisors accompany clinicians on visits and doing components of a mock survey that include role-played interviews during the visits," she tells Eli. "Surveyor interviews can also be simulated in the office, but that is not as useful as doing them in patients' homes."

Bonus: In addition to giving clinicians interview practice, it gets supervisors out into the field, Zuber praises. Don't just lob softball questions to staff during this role playing, Hogue counsels. Zero in on problem areas you expect surveyors to focus on.

4. Rotate the "surveyor" role. It doesn't always need to be supervisors asking the interview questions. Management should ID potential survey hot spots, then "staff members should act as surveyors interviewing other staff members about the particular incident or problematic area," Hogue advises. "Agencies may use consultants in this role, too," she adds.

5. Include management as subjects of mock interviews. Expect to see more interviews of management staff as well, Zuber points out. That means they need to practice being interviewed too.

6. Don't wait until the last minute. "We ... recommend that agencies not wait until a month or two before they expect their survey" to conduct the practice sessions, Zuber says. "Getting folks comfortable with these interviews may take some time."

7. Coach your employees. It's perfectly alright to train your employees on how to respond to surveyor questions, experts stress. For example, "make sure staff members avoid speculation and speak only about what they know for sure," Hogue  advises. And "it is also important for staff members to say that they don't know or cannot remember, if either is the case."

8. It doesn't hurt to ask. HHAs can ask surveyors if a manager can be present when the surveyor questions staff or patients. "Surveyors may not allow them to be present, but it's worth asking," Hogue offers.

9. Consider your corporate culture. Do your employees feel like part of the group, or are they on the outside looking in as company-wide decisions are made? That may make a big difference in how they answer surveyors' questions.

Smart agency administrators will value all employees and include all employees in appropriate discussions about how the agency operates -- "performance  improvement activities, confidentiality of health information, employee safety etc.," Laff says. "The inclusion in discussions about important issues makes employees feel more a part of what is going on."

And "agency administrators should educate senior management and middle management employees about 'attitude' and the importance of their behavior around other employees who may misunderstand slips of the tongue," Laff adds.

Keeping employees in the loop is especially important if the agency is about to go through a big change such as a merger or sale, Laff suggests. "Employees who are not included in any discussions with managers about changes ... as well as best practices or newly implemented processes will often react negatively to questions about the agency from surveyors," Laff reports.

Warning: "Informal interviews with employees who may not be 'on the list' are a very effective method of garnering information about the agency," Laff says.