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1
Judith KariGlenda Payne & The Transition Team
Using the ESRD Survey Process for the 2008 Conditions for Coverage
2
Objectives of This PresentationDescribe the expectations & challenges of an ESRD surveyRecognize ESRD standards of care & how these are used by surveyorsDescribe tasks to be used to conduct the new ESRD surveyDescribe data available to ESRD surveyors & its use in ESRD surveysDemonstrate understanding of use of findings in constructing DPS & findings for CMS 2567
3
Spectrum of ESRD Services“ESRD benefit” & the ESRD CfC cover:
Outpatient dialysis in ESRD facility• In hospital (“hospital based”) or• Outside hospital (“independent”) or• Special purpose (for 8 months max.)
Training & support for home/self dialysis
4
Hospital-Based Dialysis
Based on integrated ownership & operationNOT…• LOCATION• Shared service agreement• Patient referral agreement
At CFR 413.174
5
ESRD Benefit & the ESRD CfC Do NOT Cover
Dialysis in an inpatient settingAcute dialysis(These are covered by hospital PPS
& surveyed under Hospital COP)
Not covered:• Pre-ESRD: Stages 1-4 Chronic
Kidney Disease (CKD)
6
CMS Expectations for State Oversight of ESRD Facilities
Conduct initial surveys as soon as scheduling allows; Tier 3 workloadConduct resurveys, FY 2009• Tier 2: 10%; must be from top 20% of
outcomes list• Tier 3: 30%; 4 year interval maximum• Tier 4: 33%; 3 year interval average
Conduct complaint surveys• When warranted• Within specified timeframes
7
Challenges for ESRD SurveysSurveys are technically & clinically complex: Not intuitiveEquipment & technologies keep changing: Need updated informationLarge number of V-tags: Over 500Recognized Standards: Need updated informationWorkload competition: Not statutorily mandated
9
ESRD Survey Focus:Protect Patient Safety & Improve Patient Outcomes
Data is used to focus surveysDuring survey, observations focus on identification of safety hazards• Water/dialysate• Reuse• Machine operation/maintenance• Direct care• IDT assessment, planning &
delivery of care
10
Using Data/Outcomes in ESRD Survey
Pre-survey:• Use Outcomes List to select facilities • Use Dialysis Facility Reports to plan
surveyDuring survey:• Use data to focus survey• Expect QAPI action if poor outcomes
identifiedPost-survey:• Data may define the citation level (i.e.
standard, conditional, or Immediate Jeopardy)
11
Direct Partners in Guidelines & Standards: Incorporated in Regulations
AAMI: • RD52:2004 Dialysate for Hemodialysis• RD62:2001 Water for Hemodialysis• RD47:2002/03 Reuse of Hemodialyzers
CDC • RR-05: “Recommendations for Preventing
Transmission of Infections Among Chronic Hemodialysis Patients”
• RR-10: “Recommendations for Placement of Catheters in Adults and Children”
NFPA• 2000 Life Safety Code
12
Partners in StandardsFDA• Approval of devices, including
manufacturer’s guidelines• Reports on malfunctionsNKF• Kidney Disease Outcomes Quality
Initiative (KDOQI)• Community-accepted guidelines for both
“minimum” & “target” outcomesNQF• Develop CPMs
13
Partners for Reference Standards
American Nephrology Nurses’Association (ANNA)• Standards for nursing care• Guidelines for careState Practice Acts
14
Surveyor Use of Standards & Guidelines
POC: The implemented POC must result in patient outcomes that meet minimum levels of defined standards
If “minimum” standards of care are not met, there must be a change to the POC implemented
QAPI: For facility: Each facility must provide care to their (group of) patients that meets defined standards
15
Measures Assessment Tool (MAT)
Developed to allow updating as Standards changeIncludes both individual targets for patients & aggregate targets for facility use in QAPIIncluded as an addendum to the Interpretative Guidance Laminate for ease of use
16
The INITIAL Survey Process
Used for new ESRD facilitiesOrganized around TASKSMinimal number of patients to interview & limited records to review for assessments, plans of care plans or patient outcomes
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The BASIC Survey Process
Used for recertificationUsed in whole or in part for complaint surveysOrganized around TASKSFocus of this session!
18
STAR: Automated ESRD Survey
Surveyor Technical Assistant for Renal Disease (STAR)An automated survey guideUses a wireless tablet PCGuides YOU through the survey processRoll-out in process
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STAR …
Automatically produces a draft of Form CMS-2567• Finds V-tags• Converts handwriting to typed text
Will be updated to the new CfC asap• Can still use STAR in the meantime• Use the crosswalk to convert findings to
new tags
20
Survey Tasks1. Pre-survey prep2. Introductions3. Tour/Observations4. Entrance conference5. Patient sample
selection6. Water treatment/
Dialysate preparation7. Reprocessing/Reuse 8. Machine operation/
Maintenance
9. Home training dept review
10. Patient interviews11. Medical record review12. Personnel interviews13. QAPI14. Personnel record
reviews15. Decision making16. Exit conference
21
Pre-Survey Activities
Review of facility file• Problems, complaints• Previous surveys
Review of data • Outcomes List• Dialysis Facility Reports (DFRs)
Contact ESRD Network
22
What Type of Data Is Available for Surveyors?
ESRD dialysis facility reports developed for States for survey purposes:http://www.sph.umich.edu/kecc/usr/usr.htm
ESRD DFRs distributed to each state every September-October
23
ESRD Data Reports for Surveys
1. Outcomes List• Rank-ordered list of facilities (#1 is
the lowest-ranked facility)• List is based on 3 factors: Adequacy
of dialysis, anemia management & adjusted mortality rate
• There is a positive correlation between ranking on the outcomes list & survey deficiencies
24
Clicker Question!!
My state uses the outcomes list to choose facilities for survey each year.
A. YesB. NoC. I don’t knowD. I don’t work for a state
25
ESRD Data Reports for Surveys
2. Dialysis Facility Reports• Facility characteristics, patient
outcomes & practice patterns in the report
• Summary text on the first five pages: compares facility data to State, Network & national levels
26
Clicker Question!!
I have easy access to the DFR for every survey.
A. YesB. NoC. I don’t knowD. I don’t work for a state
27
ESRD Data Reports for Surveys
2. Dialysis Facility Reports • Charts for the following:
Standardized mortality rates (SMRs) under 1.00 are better than average—the lower the betterAdequacy: Kt/V of 1.2 or greater is targetHematocrit level 30-36% or hemoglobin level of 10-12 mg/dL are targets
• These data are COMPARATIVE—updated numbers from the facility may not be comparative
28
Clicker Question!!
I routinely use the DFR for every survey.
A. YesB. NoC. I don’t knowD. I don’t work for a state
29
Why Do Surveyors Use Data?
To SELECT facilities to surveyTo FOCUS the survey process onsite (look at current data, QAPI)To DETERMINE the extent of noncompliance (enforcement)
30
What Other ESRD Data Is Available?
Dialysis Facility Compare (DFC): facility-specific data for the public at www.medicare.gov/dialysisNetwork data: annual reports & other data at www.esrdncc.orgClinical Performance Measures (CPM): region-specific data on clinical performance measures at www.cms.hhs.gov/CPMProject/01_Overview.aspUnited States Renal Data System (USRDS) Annual Report at www.usrds.org
31
Coming Soon… CROWNWeb
New CfC requires all facilities to submit data electronically starting 2/1/09Will provide data on 100% of patients from each facilityDFRs in future will come from this source
32
Survey Tasks1. Pre-survey prep2. Introductions3. Tour/Observations4. Entrance conference5. Patient sample
selection6. Water treatment/
Dialysate preparation7. Reprocessing/Reuse 8. Machine operation/
Maintenance
9. Home training dept review
10. Patient interviews11. Medical record review12. Personnel interviews13. QAPI14. Personnel record
reviews15. Decision making16. Exit conference
33
“Our Survey” Data Shows
DFR shows 76% of the patients have hematocrit (Hct) > 30% (State average = 89%)
34
Surveying Is Like a Puzzle
It takes more than 1 piece to solve itYou may have a different view at the end than you did at the beginning!
35
Task 2: Introductions
Is BRIEFIntroduces the members of the team to the person in chargeBriefly explains the purpose of the survey
36
Task 3: Tour/Observations
Ongoing throughout surveyPhysical environmentInfection controlPatient/staff interactionPatient care deliveryStaffingMedical records/logs in use
37
Task 3a: Environmental Tour
3a: ”Flash survey” of all areas:Waiting roomPatient restroomsReuse roomWater /Dialysate areasHome training areaTreatment areaIsolation
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During the Tour
Is the environment safe & sanitary? (V111, 112, 122, 401, 402)Free of hazards? (V401, 402) Are patients treated with respect? (V452) Are machine alarms set & responded to? (V402, 757)
(From your new laminate on the survey process)
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Observe CareAre staff following CDC recommendations & these regulations for prevention of transmission of infections? (V113, 115, 116, 117 & more!)Are current records complete? (V726, 326)Do staff respond to patient problems? (V543, 544, 546, 547, 549)Is a Registered Nurse present? (V759)Are trainees supervised? (V715, 760)
41
3c: Emergency Equipment
Review for equipment function (V413)Staff emergency preparedness (V409, 411)Evacuation supplies present/in date (V408)Fire extinguishers present (V417)
42
“Our Survey” Data Collection
During observations on 10/19/08 at 9:30 a.m., 12 of 18 dialyzers from the first shift to be reprocessed are noted to be bright red
43
Task 4: Entrance Conference
Purpose/ anticipated scheduleCMS 3427 to completeCollect facility specific info: use STAR or worksheet & reference materials listRequest patient sampling info
44
Task 4: Entrance Conference
Review the facility-specific data report with the managerAsk for current data
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Task 5: Patient Sample Selection
10% sample (min=5; max=15) Sample to include variety—all treatment modalities offered must be representedUse info requested from facility to choose sample
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Sample Selection
Current patient census by modality, with admit datesCurrent HD patient listing by shift (seating chart)Cumulative lab reportsInfection logsHospitalization logsVascular access informationAny pediatric patientsResidents of LTC facilities
“Our survey” sample would include some patients identified from cumulative lab reports as “challenges” for anemia management
47
Task 6: Water Treatment & Dialysate Preparation6a-Observation/ Interview
Talk to the people doing the work“Walk me through the waterRequired components:• TWO carbon tanks; 10 min EBCT
(V192, 195)• RO (V199, 200) or DI (V202, 203)
Observe chlorine /chloraminetesting (V196, 197, 270)
48
Task 6b: Review Of Water Treatment Logs
Chemical analysis (V201, 206, 177)Microbial surveillance: monthly CFU & EU (V213, 254); response to action levels (V178, 255)Ch/chl testing (V196, 197, 270)Daily logs: hardness (V191); RO/DI parameters (V199, 202)
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Task 6c: Review Of Dialysate Prep & Delivery
Observe mixing if possibleBatches mixed on site:• Per DFU (V226)• Batch tested & verified (V229)• Bicarb not overmixed (V234)• Bicarb storage minimized (V233)All containers labeled (V228)
Outlets labeled/color coded (V245, 246, 247)Jugs: rinsed daily (V243), disinfected weekly (V244)
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Task 7: ReuseTask 7a: Observations Of
Reprocessing Procedures/Interview With Reuse PersonnelObserve the entire reuse process:• Set up for use• Take down• Rinsing• Testing• Filling with germicide• Storage
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Task 7b: Review of Reuse Logs
Reprocessing logs (V326)Germicide vapor testing (V318)Cultures/ LAL (V205, 314)PM/repairs (V316); tested after repairs (V317)QA: required audits done (V362-368); reviewed in QAPI (V635)
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Task 7c: Centralized ReprocessingNote: Surveyor must review tasks
7a & 7b at the centralized reprocessing locationP&P at user ESRD facility for transportation & clinical use (V306)Safe transport of dialyzers (V331)
53
“Our Survey” Data Collection (cont.)
During observation of reuse practices at 10:00 a.m. on 10/19/08, you see that 6 of the 12 dialyzers used by patients on the first shift are dark red when brought to the reprocessing area for rinsing & reprocessing. 3 of these belong to the patients you interviewed, & they rinsed clear.
54
Task 10: Patient Interviews
Try for a minimum of 5 patientsCan be same sample as records reviewed or differentDone in treatment area, waiting room, in private, or by phoneUse a structured interview guide—in STAR, our guide or “custom”
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Patient Interview Guide
Ask the following:How do you participate in your Plan of Care?* (V541, 556)How does your dialyzer look when your treatment is finished—clear, pink or red?**(V547)
(*=standard; **=custom)
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“Our Survey” Data Collection
During patient interviews, 3 of 5 patients tell you their dialyzer is always red when their treatment is finished These 3 patients (#s 2, 4 & 5) were interviewed 10/19/08 from 11:30 to 1:15
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Task 11: Medical Record ReviewReview 3-7 sampled records completely; focus remaining reviews on identified concernsUse STAR or the record review worksheetNew focus: patient assessment & POC developmentRefer to the MAT for current standards; if not met for individual patient, expect Δ to POC
58
Task 11: Medical Record Review
How will we know the POC is implemented?• Physician’s orders• Laboratory values• IDT progress notes • POC changes/ updates• Dialysis flowsheets
5959
Task 11: Medical Record Review
Current txorders:• Time• Frequency• BFR/DFR• Dialyzer• Heparin dose• ESA? Dose?• Iron Rx?
Flow sheet:• Tx delivered as
Rx?• Freq of B/P checks
during tx as patient needs?
• Are febrile reactions addressed?
• Assessments?
6060
“Our Survey” Data Collection (cont.)
Laboratory reports for 3 patients who indicated their dialyzers are always red show a fall in Hct over the last 3 months; 2 additional records reviewed did not have this finding. Review of care plans, orders & progress notes finds no evaluation of the fall (Reviewed on 10/20/08).
6161
Task 12: Personnel Interviews
Done during the survey:“talking to the people doing the work”Will include the nurse manager, water tech(s), reuse tech(s), patient care tech(s) & other nurse(s)May include MSW, RD & medical director If you have CfC findings, or findings related to medical director responsibilities, be sure & interview him/her
62
“Our Survey” Data Collection
Nurse manager tells you that every dialyzer is to be rinsed clear when patient’s blood is returned at the end of treatment
63
“Our Survey” Data Collection
3 patient care techs (#s 7, 9 & 12) tell you they have to finish the first shift of patients by 9:30 a.m. & sometimes they shorten the rinse-back procedure so the second shift of patients can start by 10:00. Interviews done on 10/20/08 from 9:15-9:35
64
Document Review
Review selected policies & procedures“Our Survey” review of facility policy (# 96-01) which requires rinse-back of blood until the dialyzer is clear unless the dialyzer is clotted & blood cannot be returned (Reviewed on 10/20/08)
65
Task 13: QAPI
13a) QAPI documentation/interviewAreas that must be monitored include:
Dialysis adequacy (V629)Medical injuries/errors (V634)Nutritional status (V630)Dialyzer reuse program (V635, 362-368)Mineral metabolism (V631)
More…
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Task 13a: QAPI
More areas that must be monitored:Patient satisfaction & grievances (V636)Anemia management (V632)Infection control (V637)Vascular access (V633)Technical functions (V627)
67
Task 13a: QAPI
Facility must prioritize those areas that affect patient safety (V639, 640)Develop and implement action plans aimed at making/sustaining improvement (V638)Home modalities included; PD outcomes reviewed separately (V628)
68
Task 13b: QAPI: ER Prep
Must address fire, power failure, water supply interruption, natural disasters & care-related emergencies (V408)Annual staff training (V409)Patient education program (V412)Annual contact with local disaster mgmt agency (V416)
69
“Our Survey” Data Collection
QAPI minutes from 10/07–9/08 have no evidence of audits of reuse & no evidence management has identified any issue with blood return post-treatment Facility staff have not reviewed their DRR
nor compared their anemia management rate of 76% with the State average of 89%Review done on 10/20/08
70
Task 14: Personnel Record Review
Review personnel document completed by facilityChoose a sample to review for orientation (V760), competency (V681), qualifications (V682-691, 694, 696), licensure (V681), certifications (V695), etc.Review PCT training & certification (V693-695)
71
Task 15: Decision Making
Review the data collectedDetermine what to cite, level of citation, & if additional observations, interviews or record reviews are needed.Organize for exit: use STAR or notes to make a list of deficient findings; start with most serious finding.
72
Task 16: Exit Conference
Provide an overview of survey activities; briefly summarize deficient practices identifiedAnswer questions Describe next steps
73
“Our Survey” Deficiency PresentedUnder the CfC QAPI:
V635: Hemodialyzer reuse program(IG: the QAPI meeting minutes
should demonstrate oversight of the reuse program …)
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Deficient Practice Statement
Based on review of data, observations, patient & staff interviews & review of records, this facility did not identify a fall in the Hct measures of 3 of 5 sampled patients as potentially related to the facility processes of reuse, impacting all 44 patients who were included in the reuse program in this facility as of the survey date.
75
Findings
1. Review of facility data revealed 76% of the patients in this facility achieved the target hematocrit level of 30% for management of anemia, compared to the average of 89% for the State
76
Findings (cont.)
2. On 10/19/08 at 9:30 a.m., 12 of 18 dialyzers used for the first patient shift were observed to be bright red after completion of dialysis, indicating blood was left in the dialyzer rather than returned to the patient.
77
Findings (cont.)
3. On 10/19/08, from 11:30 to 1:15 a.m., interviews of patient #s 2, 4 & 5 found that their dialyzers were “always red” when their treatments were completed. A dialyzer that is red in color after treatment is completed indicates clotting of the dialyzer or incomplete rinse-back of the blood in the tubing & dialyzer.
78
Findings (cont.)
4. Observation of reuse practices at 10:00 a.m. on 10/19/08 found 6 of 12 dialyzers from the first patient shift were dark red when brought to the reprocessing area. These 6 included dialyzers for patient #s 2, 4 & 5. These dialyzers rinsed clear & were not clotted.
79
Findings (cont.)
5. Interviews of staff member #s 7, 9 & 12 on 10/20/08 from 9:15 to 9:35 revealed they “had to finish” the first shift of patients by 9:30 a.m. & that they “sometimes shorten” the rinse-back procedure.
80
Findings (cont.)
6. Review of records on 10/20/08 for patients 2, 4 & 5 revealed lab reports showing drops in hemoglobin over the past 3 months:
Jul. Aug. Sept. Patient 2: Hct 33.1 30 28Patient 4: Hct 30 29 27.8Patient 5: Hct 31 29 27There was no evidence in progress notes, plans of care, or orders of evaluations for reasons for the drops in Hct.
81
Findings (cont.)
7. Review of facility policy # 96-01 on 10/20/08 revealed staff were required to rinse back the patient’s blood until the dialyzer was clear unless the dialyzer was clotted & blood could not be returned
82
Findings (cont.)
8. Review of QAPI minutes from October 2007-Sept 2008 on 10/20/08 at 3:00 p.m. found no evidence of:a. Audits of reuse practices b. Identification of any issue with blood
return post-treatment c. Comparison of the facility’s anemia
management rate of 76% with the State average of 89%
83
Findings (cont.)
All record review findings were verified with the nurse manager at the time of the finding.*****************************
84
Goal: Positive Patient Outcomes
The renal community, State agency & Network work together to improve patient outcomes!
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We Challenge You to Continue aLifetime of Learning:
WaterReuse Infection controlMachines & equipmentClinically complex patients!