Overseeing the overseers: CMS remains unsatisfied!

I don’t think it’s any secret that the folks at the Centers for Medicare & Medicaid Services (CMS) have been relentlessly nipping at the heels of the various accreditation organizations (AO), including (perhaps most notably) our friends from Chicago. I suppose when one looks at the overall picture of healthcare and accreditation, if the aim of the whole pursuit is (as has oft been stated) continuous readiness, then there’s probably a fair distance for travel before there’ll be any let-up of the oversight process. If one accepts that the human condition is a little bit shy of perfection, then there are an infinite number of opportunities for improvement and, consequently, an infinite number of survey findings to be had.

At any rate, the most recent manifestation of CMS’s intent to keep the improvements coming (for which the comment period closed in April) focuses on an expansion of the scope of onsite surveys to include all off-site locations, eliminates things like daily huddles during surveys, limits how accreditation organizations can “sell” consulting and education services to client facilities, and requires AOs to have their surveyors take CMS education courses (and pay the surveyors to receive that education, which makes sense to me). If you want to see the details of the proposal, you can find them here. If this goes through, I guess we can expect longer survey “visits” and a less clear idea of the results of the survey until the preliminary report is provided at the end of the survey visit—presuming that’s going to be allowed to continue. I know when there’s a state/CMS survey, one generally doesn’t know where the chips are falling until the actual report is delivered.

The proposal does have to be approved by Congress who, presumably, could be swayed by the various comments. I did a quick review, and it looks like a 50/50 split between the pros and cons. (I can’t say that the layout of the comments, etc. is the most user friendly interface, but with a little sticktoitiveness, you can wade through). It will be interesting to see what becomes of this.

I can understand the desire for a more complete picture of care being provided in all of an organization’s environments, but I do hope that a standardized approach and education program for surveyors is part of the end-product. Far too often I’ve seen surveyor overreach/overinterpretation of conditions and practices in the physical environment, often to the point of organizations having to “chase” corrective actions and “fixes” that are not only unnecessary, but sometimes overcomplicate regular operations. There will always be imperfections, but there has to be a means of responding to survey results in a prioritized fashion. Perfection is always the goal, but the human element probably isn‘t going to get us there any time soon.


About the Author: Steve MacArthur is a safety consultant with The Chartis Group. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is an advisory board member for Accreditation and Quality Compliance Center. Contact Steve at stevemacsafetyspace@gmail.com.