Investigating Complaints Against ESRD Suppliers

5160 - Investigating Complaints Against ESRD Suppliers (Rev. 88, Issued: 08-27-13, Effective: 07-19-13, Implementation: 7-19-13) 1. General Refer to the guidance for investigation of complaints against non-deemed providers and suppliers. See SOM §5200. The ESRD Networks are required to have a complaint /grievance resolution system. Networks (NW) and the SA are frequently contacted by the same complainant with the same or similar allegations. If the allegations require an onsite investigation or allege potential risk to patient health or safety, the SA is responsible for the investigation. If the allegations are primarily focused on relationship or communication issues, the NW may assume primary responsibility for the investigation. If the focus of the allegations is a medical practice issue, the SA and NW may need to collaborate on the investigation. The NWs and SA are encouraged to communicate and collaborate to reduce or prevent redundant investigations. 2. Conducting the ESRD Investigation The SA surveyors must use the ESRD survey protocol in Appendix H to investigate complaints. The allegations of the complaint will determine the tasks needed. For example, an allegation of inadequate patient care staffing would require use of the following tasks, at a minimum: • Pre survey activities; • Entrance Conference: Provide an overview of the complaint allegations and the planned agenda for your survey time; • Tour and observations; • Patient interviews; • Staff interviews; • Record reviews; • Review of quality management materials; and • Exit conference. Conduct each of the identified survey tasks in Appendix H, “Guidance to Surveyors: End-Stage Renal Disease Facilities.” 3. Pre-survey Task for ESRD Complaint Investigations Review the allegations of the complaint to identify needed survey tasks. Review the State Outcomes List and the Dialysis Facility Report to determine if there are data outliers related to the allegations. For example, if the complaint alleges staff members do not wash their hands, the surveyor should review the facility’s rate of hospitalization and hospitalizations related to septicemia, and consider this information in the survey process. To facilitate meeting the requirement of surveying each ESRD facility every 3 years, the SA evaluates all available information (outcome list rank, Dialysis Facility Report, time since last survey, complaint history, NW information, etc.) to determine whether a recertification survey should be conducted at the time of the complaint investigation.