Thursday, April 18 | EHR Solutions and Operations, Legislative/Policy, Post-Acute Care, Thought Leadership, Value-based Care

Survey Success: Proactive Strategies for Hospice Survey Preparedness and Response

By Dawn Cheek, Director, Clinical Consulting, McBee

Staying up to date with survey processes in hospice care helps you work towards ensuring quality, safety and operational efficiency. The year 2023 brought significant changes to the hospice survey landscape, with implications that resonate into 2024. 

A recent discussion highlighted changes in hospice survey methodologies, insights into deficiencies from 2023 surveys and strategies for navigating the new survey process. These changes stem from a broader effort to address common concerns and inconsistencies in survey results identified by the Office of Inspector General (OIG) in 2019.

One of the pivotal developments is the Consolidated Appropriations Act of 2021, which mandated revisions to survey procedures and emphasized the involvement of multidisciplinary teams in the survey process. This shift aimed to enhance objectivity and standardization across surveys conducted by various entities, including state agencies and accreditation bodies.

In 2022 there were significant regulatory updates, marked by the introduction of enforcement remedies and the publication of survey results by the Centers for Medicare & Medicaid Services (CMS) in 2023. These changes underscore the heightened focus on accountability and transparency within the hospice sector.

Enforcement remedies, including civil penalties and Medicare payment suspensions, underscore the consequences of non-compliance with regulatory standards. Additionally, the establishment of the Special Focus Program reflects a proactive approach to addressing persistent deficiencies and ensuring ongoing quality improvement.

To find success in an evolving regulatory landscape, hospice agencies must prioritize compliance, quality of care and patient safety. Preparing for surveys now requires comprehensive pre-survey assessments, leveraging tools like Hospice Compare scores, and understanding community perceptions.

The revamped survey process highlights core requirements related to patient rights, assessment and care planning. It requires meticulous attention to detail and collaboration among interdisciplinary teams to ensure compliance and quality outcomes.

Addressing associated conditions of participation, such as infection control and coordination of services, requires a holistic approach to care delivery. From training staff on updated protocols to facilitating seamless information sharing within the interdisciplinary group, agencies must foster a culture of continuous improvement and accountability.

As we look toward the future, hospice agencies must adapt to regulatory changes and emerging best practices. With the Special Focus Program set to roll out additional details in 2024, agencies should proactively address areas of concern and prioritize ongoing staff education and quality improvement initiatives.

With the Hospice Special Focus Program, CMS wants to identify and address underperforming hospices. Through the consolidation of data from various sources, including standard surveys, complaints and caregiver experience, CMS identifies hospices for inclusion in the program.

Once identified, hospices in the Special Focus Program face increased regulatory oversight, including more frequent surveys and audits. The goal is to drive quality improvement and ensure compliance with regulatory standards. Hospices selected for the program are publicly listed on the Special Focus Program website, enhancing transparency and accountability.

The eligibility criteria for the program includes key performance indicators, including compliance with COPs, caregiver experience and quality reporting. By using a standardized methodology, CMS hopes to ensure fairness and consistency in the selection process.

To achieve success in hospice surveys requires a proactive approach to compliance and quality. Prioritize constant survey readiness at all levels of your organization to stay ahead of regulatory requirements and to help keep an eye out for possible deficiencies. Organizations will want to regularly review and improve processes related to care planning, coordination of care and documentation.

Using technology is a way to aid compliance and quality. Electronic health records, reporting systems and analytics platforms can assist data-driven decision making, and target operational efficiency. By utilizing technology, hospice agencies can work towards streamlining operations, improving communication and deliver high-quality, patient-centered care.

Preparing for a hospice survey can be daunting, but with the right strategies and preparation, hospice agencies can navigate the process successfully. Here are some practical tips and advice to help you and your team be prepared for survey visits:

  1. Practice Being Prepared: Regularly practice being prepared for survey visits. Practice helps develop a calm and collected response, avoiding any stress when surveyors arrive unexpectedly.

  2. Create a Welcoming Environment: Designate a comfortable space for surveyors, away from traffic flow, with access to amenities like restrooms and refreshments. 

  3. Identify Primary Survey Managers: Designate a primary survey manager and a backup. This ensures smooth coordination and communication during survey visits.

  4. Prepare a Comprehensive Binder: Have essential documents and information that may be requested during surveys on hand. Include current census, employee and volunteer rosters, discharge records, policies and procedures, and more.

  5. Provide Only What's Asked For: When providing documents to surveyors, only give them what they specifically request. Keep a copy of everything you provide and maintain a list of documents provided for reference.

  6. Be Transparent About Document Availability: Communicate openly with surveyors about when any requested documents will be provided. Transparency can keep the survey process running smoothly.

  7. Be Prepared for the Unexpected: Anticipate unforeseen circumstances, such as inclement weather or unexpected events, and have contingency plans in place. Maintain flexibility and adaptability to handle unexpected situations gracefully.

  8. Stick to the Facts: Encourage team members to stick to the facts when interacting with surveyors. Avoid gossip or providing unnecessary information, focusing instead on providing accurate and relevant information as requested.


By using these strategies and fostering a culture of readiness and professionalism, hospice agencies can improve their survey preparedness and work toward positive outcomes during survey visits.

Meet the Author

Dawn Cheek · Director, Clinical Consulting, McBee



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