HHS attorney offers helpful hints. If you're wondering what surveyors will be targeting next - and how to stay one step ahead of the Internet-only State Operations Manual - take heed of some advice provided by Anne Hall, assistant regional counsel with the HHS Office of the General Counsel, Region IX. Hall spoke at a recent American Health Lawyers Association conference in San Diego.
1. Know how your state's prevalence of certain quality outcomes compares to the national average. The Centers for Medicare & Medicaid Services has quality improvement goals to reduce the prevalence of pressure ulcers, restraint use, and chronic and short-term pain in nursing homes. Hall predicted facilities may see more survey activity in these clinical areas in states that exceed the national averages.
Proactive strategy: State-based quality improvement organizations will be working with facilities to target these clinical issues, so tap into their resources or even seek their consultation to address a problem area, suggest survey experts.
2. Recognize that the Internet-only State Operations Manual is now a constantly evolving document and make sure to preserve the version you need. In other words, here today and gone tomorrow, which can be a problem if you need to refer to the requirements or language in place at a certain time to address a survey concern. Hall's advice: "Keep an eye out and print sections" to address a particular concern, she advised. "State survey agencies and regional offices should have paper copies of the manual, too," she added.