CMS Clarifies Surveyor Training Instructions

Posted on Wednesday, September 23, 2015 9:20 AM

CMS has provided clarification in its survey training instructions regarding citing home health agencies (HHAs) for Condition-level deficiencies. CMS revised the HHA survey protocols in 2011; the revised protocols provide guidance to surveyors for when a Condition-level deficiency should be considered. According to NAHC, CMS’ training implied to surveyors that whenever a Condition-level deficiency is considered, the Condition should be cited. In CMS’ clarification, CMS states the protocols are to serve as a guide and not be so prescriptive as to preclude surveyor judgment when determining when to cite a Condition-level deficiency:  “When surveyors determine that expected outcomes have not been met for the various standards/tags within a Condition, the HHA Survey Protocol provides HHA-specific guidelines for when surveyors may consider citing the actual Condition at issue. Previous trainings advised surveyors that the phrase “consider citing the Condition” in the protocol implied the surveyor “should” cite a Condition-level deficiency. This emphasis in training supported a more prescriptive application of the protocol. We have revised our training to indicate that surveyors may consider citing the Condition when indicated by the regulation, but the phrase should not be taken as a prescriptive element of the guidance over surveyor judgment. The protocols serve as a guide to assist surveyors in determining non-compliance at the Condition-level, but when the phrase “consider citing the Condition” is used the intent is to ensure that the citation be carefully evaluated with respect to evidence and is not intended to preclude surveyor judgment.” Click here to view the Survey and Certification Memo. Click here to read more.

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