The information contained herein further enhances the information provided in Section I of Achieving Substantial Compliance entitled, "The Surveys." If you are placing this information in your manual, it is suggested you insert it at page 30.

HCFA has issued revisions to the State Operations Manual which directly relate to how state survey agencies must conduct future surveys. Effective January 1, 1999, at least ten per cent of all surveys must be held during hours not considered to be "standard business hours." This indicates that surveyors may be expected to arrive at a facility at anytime, including early morning hours, late evening hours, holidays, and/or weekends. These changes in the survey process were prompted primarily by recent White House Quality Initiatives and studies conducted by the General Accounting Office.

HCFA defines normal business hours as Monday through Friday between the hours of 8:00 AM and 6:00 PM. Also included in the new SOM provisions are criteria to further reinforce the requirement that surveys be unannounced. In establishing such criteria, HCFA now requires that all surveys must be held in a nonsequential order when compared to the last survey. In other words, if state survey agencies have traditionally followed a survey pattern in certain geographical locales, they may no longer do so. The purpose of this provision is to further prevent facilities from anticipating the timing of surveyor arrival. Moreover, the month in which the previous year's standard survey was held is now not to coincide with the month of the current year's survey.

Facilities should be aware that one of the likely requirements of staggered survey start times will be the expectation on the part of the survey team that the information they require from facilities will still be available in a timely fashion. This will require facilities to develop contingency procedures to insure the facility is capable of providing such information as resident rosters, the resident census and condition of residents reports, and important facility contact information to the survey team at the time of entrance.

Additionally, although not yet in regulatory form or included in the SOM so as to have the enforcement effect of regulation, is the newly designed mechanism for "focused surveys." HCFA has begun to identify a minimum of two facilities in each state venue classifying them as "special focus facilities," subject to a more intense survey process. Facilities are so classified on the basis of a combination of previously cited deficiencies, scope and severity of deficiencies, and substantiated complaints. Facilities are assigned a weighted score based on these criteria and then ranked, with HCFA now selecting those facilities with the highest score in each state. Facilities identified as targeted focus survey facilities can now expect two, rather than one, standard survey within a calendar year. Additionally, these facilities will also be subject to interim monitoring by the state survey agency. Each facility so identified will have baseline information compiled and this information will be reported by the state to HCFA on a monthly basis.

In compiling its scoring system to determine those facilities identified as requiring focused surveys, citations for substandard quality of care are given more weight than other deficiencies, and substantiated complaints are also weighted heavily to increase the impact of complaints on the total score. HCFA claims the list of special focus facilities will be modified on an annual basis.