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Already finalizing an infection control survey for hospitals, the Centers for Medicare and Medicaid Services (CMS) has expanded the scope of the program to assess compliance with quality improvement and discharge planning during the same visit. The original plan was to conduct the three surveys — which are all in a “pilot” testing phase — during separate inspections, but linking them brings the CMS more in line with the broader patient safety goals of its Partnership for Patients program.
It also reflects awareness that infection prevention and other issues must be addressed across multiple departments and indeed the entire care continuum to be effective, says Ruth Carrico, PhD, RN, CIC, an associate professor at the School of Public Health and Information Sciences at the University of Louisville, KY.
“I think all infection preventionists realize that infection control is part of patient safety,” she says. “So the fact that they have pulled these surveys together is not surprising, nor to me is it particularly problematic. It really demonstrates that CMS recognizes — as should we — that patient safety is a ‘systems’ issue. We have spent a lot of time in infection prevention saying don’t focus on correcting a single problem or a single issue — look at the root cause, look at how your systems activities and your system structure either enables this error or prevents it. The fact that CMS is pulling all of these together and taking more of a systems approach — to me this is really the way to go.”
According to a CMS official who spoke on a condition of anonymity, there have been “slight changes” in the infection control survey based on feedback from CMS surveyors and from the infection control community. The finalization process is continuing with the CMS working in collaboration with the Centers for Disease Control and Prevention, but no major changes are anticipated as the CMS completes the process in coming months. Earlier versions of the CMS pilot infection control survey have generally received favorable reviews for its design and attention to detail by infection preventionists. Indeed, some see the survey program as a potential game-changer for infection prevention, particularly if CMS strengthens its ties to conditions of participation and ultimately links survey results directly to reimbursements. (See HIC June 2012 pp. 61-65)
“[Our] surveyors were extremely positive and liked that fact that they knew exactly what to look for, they liked the questions, they liked the way that it was organized, so from the surveyor side it was extremely positive,” the CMS official said. “The pushback we got from the professional organizations and the infection control organizations was based primarily on the wording of the questions and whether they were in alignment with CDC guidelines. We actually did make a few [wording] changes.”
No citations are being issued during the ongoing pilot testing of the CMS surveys. Though CMS officials estimate the infection control survey will be finalized in the next few months, it is not clear when surveyors will begin using the final version. The final version will be released publically, with plans calling for it to be added to the formal survey process sometime thereafter.
“Our intention — and don’t ask me when — is that once this tool is finalized, it will be used as part of the survey process,” the CMS official said. “When we use a final version and we put it out there with instructions to the surveyors that they must use the survey tool on all of their surveys then yes, they will cite deficiencies.”
However, the CMS continues to weigh its options and evaluate the surveys, seeming somewhat noncommittal about whether they will be ultimately used to inspect and cite hospitals in formal CMS surveys. “My guess is as we get closer to the end of the fiscal year we will put together our priorities for the coming year and then decide where we go from there,” the CMS official said. “I hesitate to tell you because we have been changing this on the fly for two years. I think we have made it better and made it in a way that really supports some of the other [patient safety] activities. The real question I think in the future is when are we going to include this as part of the [formal CMS] survey process — that I can’t tell you.”
Regardless, to the extent the survey reflects and codifies CDC guidelines, it could prove to be a highly useful risk assessment tool for infection prevention in hospitals.
“Even without this [infection control survey] becoming a ‘formal’ CMS regulatory tool — let’s say it morphs into an implementation and assessment tool only for health care facilities to promote patient safety — with rare exception the CMS has hit the target,” says Patti Grant, RN, BSN, MS, CIC, director of Infection Prevention and Quality at Methodist Hospital for Surgery in Addison, TX, and 2013 president of the Association for Professionals in Infection Control and Epidemiology. “It is obvious CMS collaborated with content experts in the field.”
Editor’s note: All three of the CMS surveys are available at: http://ow.ly/hJt1C
For more on this important story see the March 2013 issue of Hospital Infection Control & Prevention