National Quality Review (NQR) - Federal Look Behind Surveys
Posted by: CQL on 01/09/2007
Filed under: Federal Projects
Centers for Medicare and Medicaid Services (CMS)
The Situation
The General Accounting Office (GAO) presented a report to the U.S. Senate Committee on Governmental Affairs on a study of the state of the federally funded ICF/MR program – serving over 62,000 people. The study followed a series of reports from advocacy organizations and the Department of Justice on problems with quality of care and protection of rights for people with disabilities residing in those facilities.
The GAO report concluded that federal oversight of the individual states’ survey processes needed to be strengthened.
CMS issued a request for proposals to strengthen Federal oversight and monitoring across the 6,600+ ICFs/MR and to take aggressive action to protect those individuals who live there from abuse, neglect and mistreatment.
CQL was awarded a five-year contract to perform the federal look behind surveys.
What CQL Did
CQL established and implemented the federal look behind and monitoring process for the Intermediate Care Facilities for Mental Retardation (ICF/MR) program – known as the National Qulaity Review (NQR). Within 45 days of the award, CQL recruited and hired a cadre of full and part time surveyors and within 55 days of the award, the first team of surveyors was deployed in the field to conduct the look behind surveys. Survey teams received initial basic surveyor training from CMS and CQL developed a training program for subsequent hires. All surveyors were evaluated for inter-observer reliability and required to maintain 85% reliability as a condition of continued employment.
Over a five -year period, working closely with CMS Central Office and Regional Offices, CQL successfully conducted look-behind surveys, follow up surveys, crisis and special investigations — over 1,100 in total. CQL developed and implemented systems for the scheduling, deployment, training, and monitoring of survey staff and provided cost analysis data for future planning. Surveyors regularly entered data into OSCAR and ASPEN and provided reports and analysis to CMS.
The survey teams:
- conducted federal look behind surveys or comparative surveys within 30 days of a State survey to assess the survey agency’s performance in the interpretation, application and enforcement of federal requirements
- conducted special investigations, including complaints, observation and monitoring reviews
- responded to crisis situations that endanger health, safety or welfare of individuals living in ICFs/MR
CQL conducted comparative analyses of state surveys as compared with federal look behind surveys. Our analysis identified:
- most frequently cited “tags” – CMS requirements or standards
- citations of failure to meet Conditions of Participation
- incidents of Immediate Jeopardy – people who were at at risk for their health or safety
- areas of difference between state surveys and the federal look behind surveys
- trends over the five-year period
- recommendations for improvements to the surveyor training and reliability process, better knowledge transfer between CMS Central and Regional offices and the state survey agencies, and additional areas for research and analysis