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The Role of QAPI in Preparing for the New Survey Process

Dr. Andy Kramer
December 4, 2017

I have been asked often about details of the new survey process, and how best to replicate it for Quality Assurance and Performance Improvement (QAPI) purposes. My response is that while the new Requirements of Participation prescribe a more up-to-date, albeit more challenging, set of quality standards and expectations for nursing centers, replicating the new survey process is neither a requirement nor an effective foundation for your QAPI program. While you want your QAPI activities to reflect the new regulations, including meeting the standards for a robust QAPI program, replicating the survey process is not the best way to accomplish this.

The comparison between QAPI and survey is a bit like studying for, as opposed to taking, a test of both knowledge and skills. Although learning the material and being able to apply the skills on which you will be tested is a requirement for success, the best way to prepare is not to restrict yourself to an equivalent block of time and a focused subset of subject matter to try to replicate the test.

Studying and practicing for a test is best accomplished over a longer period of time where fundamental concepts become ingrained in a manner that is organized for learning.

‘Replicating the exact test conditions may help along the way to gauge your preparation, but it is not the way to learn the material or skills.’

QAPI, like studying, is a continuous learning process that you conduct with the goal of progressively assessing and improving care and services. Surveyor methods for sampling and conducting investigations, and the software tools they use, are designed for a survey to be conducted in about a week, and their end point is the statement of deficiencies. Your QAPI program should be an ongoing process over time, and your end point is improved quality of care.

Spending your time trying to identify the specific residents that surveyors will investigate is not the goal of QAPI, nor survey preparation. At the same time, it is important to make sure that the care issues that are emphasized in the survey are part of your QAPI plans and survey preparation. It is important to hold yourself to the standards that are articulated in the regulations by applying those standards in QAPI activities that are conducted throughout your organization—seeking system-wide solutions where needed.

Available materials documenting the regulations and survey investigations can provide a basis for many of your QAPI processes. In fact, with the new regulations there is much to be learned if applied in a structured QAPI program where you focus your attention on the most critical care issues. One size does not fit all organizations, however, and you need a program that works for your resident population and your organization.

The challenges that all providers are now facing with so much changing are evident. Even the Centers for Medicare & Medicaid Services has signaled that it understands that these changes will be a learning process for both surveyors and providers.

Provider Magazine – December 2017 issue

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