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CMS surveys take over your life if you’re a dialysis facility administrator.  For the four to five days the surveyors, usually from the Department of Health Services (DHS) are in the unit, you get very little else done. Then they leave and the work really starts.

How much of everyone’s time this will take depends on how many V tags are cited.  The DHS surveyors will find deficiencies even in the best run facilities.  And the Interpretive Guidelines make it clear that many identified problems can be cited under more than one V tag.  Many surveyors will cite a single identified problem in multiple locations, multiple V tags. How much time it will take to address problems is also dependent upon the seriousness of the citations.  Are they Condition Not Met level or Standard Not Met level?  Is the issue patient safety or housekeeping?  Overall, the more V tags, the more serious, and the more time consuming to fix. 

*Note that time is described as Personnel Hours.  Personnel Hours = Number of hours needed for the activity times the number of people involved in each activity.  The estimates are approximate of course.

Post-CMS-Survey

Personnel Hours* required for activity.

Activity

>10 V tags

< 10 V tags

Organize the CMS/DHS summation conference notes into a presentable format.  Prepare for meetings (outlined below) to communicate preliminary findings.

2

1

Meet with dialysis leadership to review the preliminary findings.

4

2

Meet with other key stakeholders (physicians and other care providers, staff, organizational leadership) to communicate preliminary findings.

10

5

Begin to develop plans of correction for identified problems.

4

2

Receive and review Statement of Deficiency (CMS-2567).

1

1

Develop with the dialysis leadership team a detailed Plan of Correction to the Statement of Deficiency, including a realistic time line for correction completion.

80

20

Prepare a written Plan of Correction response to each V tag given in the Statement of Deficiency for submission to DHS within 10 business days.  Review the response with leadership team members to assure accuracy of proposed correction and time line.

16

4

CMS/DHS re-survey visit, including conference and interview time, documentation preparation, review and discussion.  If minimum deficiencies, DHS will sometimes by-pass re-survey visit for documentation submission only.

32

16

Organize the CMS/DHS re-survey summation conference notes into a presentable format.  Prepare for meetings (outlined below) to communicate re-survey findings.

2

1

Meet with dialysis leadership to review the re-survey findings.

4

2

Begin to develop plans of correction for identified unresolved/new problems.

2

1

Receive and review re-survey Statement of Deficiency.

1

1

Develop with the dialysis leadership team a detailed Plan of Correction to the Statement of Deficiency.

40

10

Prepare a written Plan of Correction response to each V tag given in the re-survey Statement of Deficiency for submission to DHS within 10 business days.  Review the response with leadership team members to assure accuracy of proposed correction and time line.

8

2

Implementation of Plan of Correction for Deficiencies

80

80

 Total Approximate Personnel Hours

286

148

Surveyors, whether CMS or your own, will find problems.  Problems will need to be fixed.  Fixing problems takes time.  But the bottom line is that fewer V tags on the CMS survey translates to less of the dialysis facility’s leadership time spent spinning bureaucratic wheels doing paperwork, 138 fewer personnel hours in our rough sample.  If the average salary for dialysis facility leadership is $50, then -

Cost: 138 Personnel Hours x $50 = $6,900
 

 

 

 

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