Preventing Survey Deficiencies Through Mock Surveys.

Today, more than ever, nursing facilities must be prepared to demonstrate compliance with federal regulations not only at survey time, but all year long. Survey teams can arrive at facilities as soon as nine months after the last annual survey. They can appear at any time to conduct complaint investigation surveys. And, these days, they are likely to begin surveys at nontraditional times and on weekends. These changes in the frequencies, times and types of surveys make it imperative that facilities be prepared at all times.

Nevertheless, with rapidly increasing turnover rates for nursing staff and managers, facility staff might not be familiar with surveyors' procedures, care observations, interviews, and record reviews and could be unprepared to meet these challenges.

To adequately prepare staff to succeed at survey time, and to ensure that the facility complies with regulations at all times, periodic mock surveys can be an important feature of a facility's quality assurance process. A mock survey can be performed by facility staff, by corporate advisors or by outside consultants. In whatever manner your facility chooses to provide these services, there are a few guidelines to bear in mind.

1. Enlist "fresh eyes" to see existing problems clearly. Be sure to include new employees, an "outsider" or other mock surveyors who are not overly familiar with the facility's staff and residents. If using facility staff, ask them to review areas outside their direct span of control.

2. Replicate "real" survey procedures as faithfully as possible. Use precise observation methods, select a sample of residents according to survey guidelines and interview the same staff that real surveyors are likely to interview.

3. Record detailed findings. Before assessing whether a deficiency exists, your mock surveyors must record "what happened to whom, where and when." This means they must name the resident (or use an identifier), accurately describe the event, note the day and time, and record the location.

4. Conduct interviews with key staff, residents and family members. Mock interviews give staff a chance to practice telling surveyors about the care they provide to residents; they also give residents a chance to voice concerns and offer families a chance to communicate problems that can be addressed before the real survey.

5. Analyze findings carefully and review multiple sources of information before determining that deficiencies exist. Mock surveyors (like real ones) must be careful not to jump to conclusions before they have all the facts. Review your state s operations manual closely to verify that actual regulations have been violated, not just interpretive guidelines.

6. Write a comprehensive report that summarizes the results of the mock survey. The final report should describe each deficiency in sufficient detail so that facility staff can understand the reasons for noncompliance. The final report can list recommendations for correcting the respective deficiencies.

In preparing for a mock survey, gather all the required documents just as you would for a real survey. Be sure you collect a:

* list of key facility personnel and their locations

* copy of the written information provided to residents regarding their rights

* record of mealtimes and dining locations, as well as copies of menus

* record of medication pass times

* list of admissions within the past month, and a list of residents transferred or discharged during the past 3 months, with destinations

* copy of the facility's layout

* copy of the facility's admission contract(s) for all residents

* list of the facility's policies and procedures for investigating allegations of and prohibiting abuse

* summary of evidence of your facility's monitoring, recording and prevention of accidents and other incidents

* current resident activity schedule

* list of names of residents age 55 and under

* list of names of residents who communicate with nonoral communication devices, or who speak languages other than the dominant language of the facility

When recording observations, consider developing and using a tool that provides guidance for an observer to record findings accurately. An example of such a tool is shown in figure 1.

For a mock surveyor's review of residents' clinical records, consider developing and using a standardized tool such as the example provided in figure 2.

When finalizing a mock survey report, it can be useful to provide a scope/ severity grid upon which to place each deficiency, so that the facility staff can see at a glance how their facility measures up. See the example shown in figure 3.

Once you run through this drill, you should be ready for a real survey at any time. What's more, your facility's resident care might be the better for it.

Beth A. Klitch, FACHCA, is president of Survey Solutions, Inc., Columbus, Ohio.