Providers are from Earth, Surveyors are from Mars

[dropcap]It is stressful[/dropcap] when a surveyor walks through the door, regardless if you are expecting a survey or not. The fear of what we will get from the outcome of the visit is often the first thing on the provider’s mind… the only thing on the provider’s mind until the visit is over… and still on the provider’s mind until the final results are given.

We hear things like “the surveyor was not fair”, “the surveyor cited us for issues that are not a regulation and didn’t bother to explain the regulation to us”, “the surveyor was in a bad mood and just nitpicked us” or  “the surveyor was so nice and helpful educating us on what we were doing wrong”. The truth of the matter is, they are all true! At least from an Earthling’s perspective! The surveyors from Mars are human too (I promise).

Short of giving a personality test to every surveyor who walks through the door, to arm yourself against all those surveyors, realize the issue is not the surveyor, it is what you are doing or not doing.  So many providers believe they are doing nothing wrong, yet fail to ask: when is the last time an owner, manager or outside party looked at the policies, regulations, charts or processes?  You can prepare to survive your next surveyor by learning what they learned to obtain the job.  We all have the handouts on how to prepare for a survey, we’ve attended seminars on the regulations and how to write a plan of correction. This is ancient advice and the tags we are cited with seem to change their meaning and we can’t seem to score a 100% on a survey these days!

Earthlings:

• Almost any issue that is found has a “place” under regulations to cite you with a tag.
• Surveyors are not in a bad mood because of you, it is because they are human.
• Surveyors are not visiting you to help you run your operation, nor to educate you.  
• Surveyors do not enjoy nitpicking your charts or business, it takes a long time to get through what they have to audit, leaving no time to find a hidden nugget of non-compliance.
• Sometimes… even the Surveyors are wrong – Yes Really!
• Surveyors really have a job to do, it’s difficult for them to know the agency may be mad, that is why you get your results after they are done and not during the survey.
• Most surveyors will give you every opportunity to prove them wrong.

Be Ready for an Invasion from Mars:

• If you purchased your Policies, read your policy manual. If a Policy is stricter than the regulation, that is what standard you will be held to.  If the regulation is stricter than your policy, that is what standard you will be held to. This is often why providers feel they were cited and it isn’t a regulation. When Policy manuals are purchased, they are not reviewed against regulations to ensure you are not set up to follow stricter guidelines.
• Think like you are from Mars.  Check out the “Guidance for laws and Regulations” (EVEN if you are not a Medicare provider) You do not need to read the whole manual, just read   “Probes” under each section.  ALL surveyors must go through extensive training to include CMS training.  There are several manuals that cover a lot of services, if you read the probes, you will understand how to think like you are a Mars investigator too .  All services overlap in some regulations that they all must follow, so its worth a look: Medicare: Provider Enrollment Guidance for Laws and Regulations
• Have some fun! Most agencies do not have time to orientate staff to anything extra than the required subjects.  It often comes back to haunt us during a survey!  If staff knew the policies  or regulations that are in place- they are less likely to do what they “think” is right and do what they know is right. You can email a policy a week to all your staff. Get a read receipt! Make crossword puzzles from regulations, email out to office staff or field staff 10 questions monthly and use 9 that pertain to specific regulations and 1 that is a weird fact such as: What is the plastic end on a shoe lace called?   Offer a small prize (Such as a movie ticket) to the first one who returns by email all 10 answered correctly. It creates a little competition as well as a little research for your staff. Send the right answers back to all staff. It’s a great way to have a little fun while educating the staff.
• Do not rely on audits done by the very people who work at the agency. It is very easy to miss a mistake over many charts if you are not aware that it is a mistake being made. Can’t afford consultants to come regularly? Utilize Consultants for a mock survey before your big surveys. It could save you from administrative fines and a save you a lot of time after the survey writing those plans of corrections!
• Be self-confident enough to disagree with a surveyor, ask where it is in writing in the regulations if you believe the surveyor is citing a tag that isn’t a regulation.
• Be knowledgeable enough to explain to the surveyor what the regulations say.  They may not interpret it the way you do.  The surveyor’s work history may be different than your service that you provide. So explain what your understanding is to the surveyor! Some surveyors learn from the agencies! We know there are so many changes, even the surveyor can’t keep up.
• Know how to make a complaint about your surveyor and not be afraid.  It can be anonymous, it can be helpful for their manager to know and it may be helpful to the next target of a survey. Did you know that if you have problems with a surveyor such as being inappropriate and disruptive while in your office, ask their manager to avoid sending that surveyor to your agency in the future?  
  • Fill out that survey card they leave!  
  • You may call a complaint about a surveyor in to the hotline at 1-800-458-9858.
  • You may email a complaint to RegInternal.Investigations@dads.state.tx.us.
  • You may complete a comment card online at Texas DADS Comment Card Survey
  • You may call a complaint in to the Regional Director for the region in which your facility or agency is located

• Always be respectful and tactful when you tell the surveyor that they are to go to a designated person for all questions and needs. If they must talk to other staff, ask that you are present to witness the questions.
• Pretend every day is survey day, next time be relaxed and cool earthling!  What solution can you implement today to help your agency to prepare? Desensitize yourself to the immediate fear of seeing a surveyor by asking daily, what issues do we have and how do we resolve it?
• Start preparing for survey today regardless of when you have a survey. Nitpick your own agency, ask the probe questions and be ready anytime for a UFO landing!

Editor’s Note: Penni’s friends at Forte Consulting Group wrote this excellent article for your benefit!  Please feel free to give them a call @ (855) 436 7834, or to visit their website at www.forte-cg.com!