The Unannounced Survey
Being prepared isn’t just for the Boy Scouts. Medicare and Accreditors both could appear at your doorstep any day, and it helps to have a plan. Because the medical equipment industry is under scrutiny, these inspections occur without advance notice, and the possibility of key managers being unavailable is real. Despite the absence of these managers, certain documents need to be quickly located, and it helps to assemble these documents so that any staff know where to find them.
Medicare and Accreditation organizations both want all the licenses and permits required for your business. A good comprehensive resource to check for reviewing your state’s requirements is: http://www.palmettogba.com/palmetto/statelicensure.nsf. This valuable site can keep you from being blindsided regarding bedding & sterilization permits, state dispensing licensure, and other unique requirements for the products and services you provide. Copies of these permits, licenses, etc. must be posted in an area where the public can see them; and you need to check that these items are un-expired.
KEY DOCUMENTS
Understand that each accreditation organization has its own unique requirements that go beyond what is listed in this article. A master sheet that identifies where the following minimum documents can be found will help staff retrieve the binders and files that your surveyor / site visitor wants to see. The documents that should be readily available are:
Performance Improvement raw data and reports
If your company is more than a handful of employees, an organization chart with names will be helpful.
The file with Incident Reports (also known as “Adverse Events”)
The file with Complaint Reports and copies of letters sent to patients within 14 days of receiving the complaint.
Your policy & procedure manual
Personnel files: where the files are located and who has access to them
Information about your last emergency drill or actual emergency (held within the last 12 months); plus the retrospective evaluation of what worked, what didn’t and needs modification
THE INSPECTION
All accreditation organization representatives will want to get started with the inspection as soon as possible after they arrive.
Although the rhythm of the inspection may vary slightly by accreditation organization, your staff should make it a priority to review the stack of delivery tickets or route logs for customers who are already scheduled for staff contact. Understanding what the surveyor wants to find is key. Most accreditation organizations do NOT want to see a new setup nor a pickup. They do not want to see delivery of a box of diapers or supplies. The surveyor will pick which patient to see your staff interacting with from the route log or delivery tickets. You have the opportunity to stack the deck and should take full advantage of that by reviewing which customers and which services are on schedule as well as which staff are going to provide that service. If your company provides respiratory products, a cylinder exchange, liquid oxygen delivery, or concentrator check is exactly what the surveyor wants to observe, because this patient has an established file and relationship with your company. If you provide rehab, a visit to a patient who needs an in-home repair or adjustment of a recently delivered chair is perfect. In the absence of anything but supply deliveries or pickups, you may need to volunteer a local customer or adjust a customer contact from another day to today. Think about who you are going to volunteer and verify their customer file meets all the requirements! The customer has the right to refuse the surveyor, and a preliminary phone call to the customer asking for permission will (or should) occur prior to the visit. The surveyor will be happy if he or she can be curbside at a customer’s home by 10am. Most surveyors do not ride along with staff in the truck or van. If a manager from your company can drive their own car with the surveyor as passenger to the client’s home, great. The first time your delivery vehicle will be observed is upon arrival at the customer home as the driver retrieves whatever is needed for this home visit.
Some staff reminders are:
Secure EVERYTHING on vehicle (hand truck, crates with supplies).
Be aware of ALL the medical equipment patient has, not just the item you are there for that day. Ask about any problems with equipment, look it over for safe installation, proper function.
Use hand sanitizer before and after home visit – share some with the surveyor!
o Remember that gloves are not a substitute for use of hand sanitizer
If you provide respiratory:
Oxygen cylinder racks must NOT be secured with a stretch cord- use non-stretch nylon webbing straps with buckle!
Verify use of oxygen against the MD signed prescription you have on file for that patient- know the liters per minute, hours /day BEFORE you walk in the door.
o If the patient isn’t using it within the parameters of the order—re-educate!!! Let the surveyor hear you re-educating!
Watch for free-standing cylinders in the patient home. If there are any- correct the situation and re-educate the patient!!
During concentrator check or swap out of equipment- do NOT take patient off oxygen for even a minute, even if the patient says it is okay. Get the backup or portable- put patient on the back-up before turning off or disconnecting the concentrator for the check.
Check oxygen output at the far end of extension tubing (verify liter flow is as prescribed at patient end) with a flow pen.
Make sure they have a NO SMOKING sign! Give them one if it isn’t up on door or entryway, and gently push them to put it up.
Assess the patients level of comprehension of use of concentrator and back-up tank; and prescription compliance.
Upon return to your facility, the surveyor will review the file of the patient visited for required demographics, orders, and documentation; then move on to review your company’s equipment cleaning and maintenance process, interviewing staff who perform this function and observing how it is done.
As noted in the ‘key documents’ list, at some point in the inspection, management will be interviewed for their knowledge and involvement in the Performance Improvement process, staff training (and personnel files), and compliance with the specific accreditation organization’s standards.