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From Health Law Daily, April 10, 2018

New ICF/IID survey protocol focuses on observation time

By Sara Cracau, J.D.

CMS revised the survey protocol in Part I of Appendix J of the State Operations Manual (SOM) for intermediate care facilities for individuals with intellectual disabilities (ICF/IID). The survey process will refocus on increased observation time and more effective use of interviews and client record reviews. The fundamental survey was revised to be a focused fundamental survey implemented through key standards and corresponding standards within the Conditions of Participation (CoPs). Tasks one, two, and three of the survey procedures are revised (CMS Letter to State Survey Directors, Ref: QSO-18-16-ICF/IID, April 6, 2018).

Survey levels. The three levels of ICF/IID surveys are: the focused fundamental survey, the extended survey, and the full survey. Apart from these three are initial certifications and annual re-certification of ICF/IIDs which require a Life Safety Code survey. A full survey must be conducted for initial certification surveys. However, a focused fundamental survey should be conducted for recertification surveys unless the State Survey Agency finds that a full survey is warranted based on identified concerns regarding the provider’s capacity to provide adequate services. The primary method of information gathering in the focused fundamental survey is observation, using interviews and record reviews to confirm or to refine information on identified concerns. Use of in-depth review of progress notes or historical data is limited primarily to situations in which non-compliance of a key standard is suspected.

Survey procedures. Task one comprises selection of a core sample of clients from a list of the facility’s current client list regardless of client developmental levels or locations in the facility. Selection should be based on one of the following criteria: admission to the facility within the previous six months; participation in a self-administration program; and/or frequent hospitalizations or ER visits. Task Two has been revised to comprise a phased approach which involves review of a facility’s systems to prevent abuse, neglect and mistreatment and to resolve complaints. Phase one focuses on client observations such as staff-to-client and client-to-client interactions and follow-up interviews. Phase two becomes relevant if there are pre-existing criteria or if client protection concerns arise in the course of the survey. Task three focuses on the areas of active treatment, staffing, the role of the qualified intellectual disability professional (QIDP), healthcare services and physical environment. If concerns arise, associated interviews and record reviews would need to be conducted. The content of tasks four through seven was not revised.

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