Team Composition

7201.2 - Team Composition (Rev. 244; Issued: 06-26-26; Effective: 06-26-26; Implementation: 06-26-26) The State (or, for Federal teams, the CMS Location) decides what the composition of the survey team will be, provided that certain statutory and regulatory requirements are met. Sections 1819(g)(2)(E) and 1919(g)(2)(E) of the Act and 42 CFR 488.314 require that: • Surveyors be free of conflicts of interest (see §7202); and • Surveyors successfully complete a training and testing program in survey and certification techniques that has been approved by the Secretary. In other words, surveyors must successfully complete the CMS-approved training and pass the Surveyor Minimum Qualifications Test. (See Chapter 4).1 of this manual for additional information concerning Surveyor Minimum Qualifications Test requirements). If a surveyor has not passed the SMQT or if the complexity of a resident’s care requires expertise of more than one discipline, surveyors should work jointly to complete the review. A surveyor must successfully complete the SMQT to survey independently, however they can serve as a team member and complete survey tasks for which they have successfully demonstrated understanding as long as they are supervised by a qualified SMQT surveyor. The supervision of the newly trained surveyor should be as hands on or direct as needed to ensure all survey tasks are completed according to appropriate survey policy and procedures. • Regulations at§488.314 require that SNF and NF initial and recertification surveys be conducted by a multidisciplinary team of professionals, at least one of whom must be a registered nurse. Complaint investigations and on-site monitoring of compliance, including through revisits, are subject to the requirements of sections 1819(g)(4) and 1919(g)(4) of the Act and section 488.332, which allow the use a specialized investigative team that may include appropriate healthcare professionals as required to investigate the allegation or concern, but need not include a registered nurse. Within these parameters, the States (or, for Federal teams, the CMS Location) are free to choose the composition of each team, and it is the State that determines what constitutes a professional. However, CMS offers the following guidance: • The State or CMS Location should consider using more than one registered nurse on teams that will be surveying a facility known to have a large proportion of residents with complex nursing or restorative needs. • Because of the strong emphasis on resident rights, the psychosocial model of care, and rehabilitative aspects of care in the regulations and the survey process, the team should include social workers, registered dietitians, pharmacists, activity professionals, or rehabilitation specialists, when possible. • It is important, to the extent practical, to utilize team members with clinical expertise and knowledge of current best practices that correspond to the resident population’s assessed needs, the services rendered in the facility to be surveyed, and the type of facility to be surveyed. For example, if the facility has a known problem in dietary areas, there should be an effort to include a dietitian on the team; if a known problem in quality of life, a social worker. If the facility specializes in the care of residents with post trauma head injuries and strokes, a physical therapist may be included on the team. • The State is responsible for determining which members of the survey team have the appropriate skills, clinical expertise, and licenses to make observations that include a resident’s genital, rectal, or the breast area. This would likely be limited to surveyors with professional licenses, such as registered nurse, licensed physical or occupational therapists, physician assistants, physicians, etc. When making these observations, surveyors must attempt to obtain consent from the resident or their representative- See Resident Privacy Section below. Additionally, surveyors must be aware of any history of trauma, and honor the resident’s preferences, including cultural and religious beliefs. • In addition to members of individual disciplines routinely included as members of the survey team, consideration should be given to the use of individuals in specialized disciplines who may not routinely participate as team members. These individuals would be available to assist the survey team when specific problems or questions arise. Consultants in these suggested disciplines include, but are not limited to, physicians, physician assistants, nurse practitioners, physical, speech, and occupational therapists, dieticians, sanitarians, engineers, licensed practical nurses, social workers, pharmacists, and gerontologists. NOTE: Specialty Surveyors - All members of the survey team should enter the facility at the same time, if possible. Specialty surveyors participating in surveys (e.g., a pharmacist, physician, or registered dietitian) must be onsite during that portion of the survey dealing with their area of expertise. However, they must conduct that portion while the rest of the team is present. Before leaving the facility, at the completion of his/her portion of the survey, the specialty surveyor must meet with the team or team coordinator to discuss his/her findings and to provide supporting documentation. The specialty surveyor should also share any information he/she obtained that may be useful to other team members. If he/she is not present at the information analysis for deficiency determination, the specialty surveyor should be available by telephone at that time and during the exit conference. • In order to comply with the requirement that “No individual shall serve as a member of a … team (surveying a SNF or NF) unless the individual has successfully completed (the CMS-approved) training and testing program,” surveyors in training, i.e., those who have not successfully completed the required training, must be accompanied on-site by a surveyor who has successfully completed the required training and testing. While it is desirable that all survey team members be fully qualified, CMS recognizes that trainees must be given opportunities to perform survey functions so that they can achieve “fully qualified” status. Participation in actual surveys is a valuable and integral part of a training program. In fact, in the orientation program designed for newly employed surveyors, CMS recommends that 3 weeks be spent in the field as part of the training.