Conducting Initial Surveys and Scheduled Resurveys

2700 - Conducting Initial Surveys and Scheduled Resurveys (Rev. 1, 05-21-04) 2700A - Unannounced Surveys (Rev. 1, 05-21-04) It is CMS policy to have unannounced surveys for all providers (including all types of hospitals) and suppliers (other than laboratories). Sections 1819(g)(2)(A)(I), 1919(g)(2)(A)(I), and 1891(c)(1) of the Act establish civil money penalties (CMPs) for any individual who notifies a SNF, NF, or HHA of a survey. (See §2008 and §7207.) While the unannounced surveys may result in some minor inconveniences, this policy represents changing public attitudes and expectations toward compliance surveys. If there is any conflict with internal State policies and practices, the SA should discuss the problem with its RO. To enhance the unpredictability of unannounced standard surveys of LTC facilities, special selection criteria are to be incorporated when State agencies are scheduling standard surveys to LTC facilities. (See §7207.) Exception: Non-LTC facilities other than HHAs may be given advance notice (usually no more than one working day before an impending survey) if all of the following criteria are met: • The facility is inaccessible via conventional travel means and it is necessary to make special or extraordinary travel arrangements; and • There is a high probability that the staff essential to the survey process will be absent, or the facility will be closed unless the survey is announced. (See §2008.) • The announced survey is approved by the RO on a case-by-case basis. 2700B - SA Schedule for Conducting Health and Safety Resurveys (Rev. 91, Issued: 09-27-13, Effective: 09-27-13, Implementation: 09-27-13) The SA resurveys and recertifies providers/suppliers on a cyclical basis in accordance with the survey coverage levels specified in the budget call letter. Surveys of SNFs, NFs, and HHAs must be on a flexible cycle in order to reduce the “predictability” of the survey. (See §2008.D.) SNFs and NFs must be subject to a standard survey no later than 15 months after the previous survey and HHAs must be subject to a standard survey within a 36-month interval. The SA surveys ICFs/IID no later than 15 months after the previous survey so that a timely certification can be ensured. The SA should consider geographical considerations and the scheduling of licensure visits so that coordinated visits can be made whenever possible. Change of Ownership (CHOWs) or other changes that may affect a provider’s/supplier’s compliance status may necessitate adjustment of the SA survey interval. (See §2702.) 2700C - Coordinating LSC Surveys (Rev. 1, 05-21-04) In most cases, the SA schedules the LSC survey to coincide with the Health survey. However the timing of the LSC survey is left to the discretion of the SAs. The SA determines whether the LSC survey is to occur before, after, or simultaneously with the health survey. If the health survey and the LSC survey are conducted at different times, data entry into OSCAR must be deferred until both surveys are completed, and the data of the latest segment of the total survey (the health portion or the LSC portion) is used for OSCAR purposes. Most States require an initial LSC survey before allowing a provider/supplier to admit patients prior to becoming operational. Regardless of the timing of the LSC survey, the SA should schedule it so that all survey and certification actions are completed timely.