April 11, 2024

Minnesota Selected for Nursing Home Risk-Based Survey Pilot Participation

On April 11, 2024 by Mark Schulz

The Centers for Medicare and Medicaid Services (CMS) informed the Minnesota Department of Health (MDH) that it has selected Minnesota to participate in their pilot for a risk-based survey (RBS) approach for nursing home standard recertification surveys.

Currently, MDH is awaiting CMS training on the revised process before it will be permitted to begin conducting the revised surveys. The anticipated start date of these risk-based surveys is not yet known. MDH has assured us they will inform us before implementing the pilot survey process. 

Background

In 2017, CMS implemented a new nursing home survey process across all states in conjunction with the implementation of revised Requirements for Participation for Long Term Care Facilities. In its only public information release to date on the risk-based survey pilot topic, CMS states it is essential to prioritize limited resources toward those compliance areas that pose an increased risk to individuals’ health and safety.

By modifying some surveys based on compliance and quality history, CMS states it will be able to devote more time and resources to nursing homes with lower quality whose residents are at higher risk of harm.

Risk-based survey approach

First announced in December 2023, CMS has been tight-lipped about the pilot until now. CMS will pilot the RBS approach to allow consistently higher-quality facilities to receive a more focused survey that takes less time and resources than the traditional standard recertification survey while ensuring compliance with health and safety standards.

CMS is exploring several indicators of high quality, including citation history, such as a history of fewer citations of noncompliance and an absence of citations related to abuse or resident harm, staffing and compliance with staffing data submission requirements, quality metrics such as hospitalizations, and other indicators (e.g., no citations related to resident harm or abuse, no pending investigations for residents at immediate jeopardy for serious harm, compliance with staffing and data submission requirements). However, CMS has not yet provided details about the exact indicators it will use to select facilities for the pilot RBS approach.

CMS estimates the scope of the new survey approach would be limited, impacting approximately 10% of providers in a state.  While the targeted survey would replace the standard survey for these providers, complaint surveys would not be affected, and a risk-based survey could be expanded to a regular standard survey as indicated by findings at the time of survey.

Providing feedback

MDH has informed us that facilities will be informed during their entrance conference they are receiving an RBS instead of a standard recertification survey.  At that time, the facility will also be instructed on providing direct feedback to CMS about the RBS approach experience and pilot.  Additionally, during these surveys, MDH will continue to provide its anonymous feedback questionnaire and encourage facilities to express immediate concerns with survey team supervisors as they would typically do.

Stay tuned for updates

We anticipate that more information will be forthcoming from CMS and MDH in the very near future as our state’s regulatory leadership heads to CMS’ annual Survey Executives Training Institute, where they will hear directly from CMS about this developing topic.

Watch Advantage for updates on this developing topic as we learn more from CMS. 

We encourage any providers selected to participate in this pilot program to email Mark Schulz to share your experiences with it.