To update the Federal Oversight Support Survey Process (FOSS) to be in line with the new Long-Term Care Survey Process (LTCSP), the Centers for Medicare & Medicaid Services (CMS) issued Admin Info:10-06-NH on January 5, 2018 that outlines the process for a FOSS national pilot that is currently underway. The FOSS pilot started this month, replacing the existing process that was used for both the traditional survey (FOSS) and the Quality Indicator Survey (FOQIS) processes and consists of two phases.
The two phases of the pilot will be conducted from January 1-September 30, 2018. Phase 1 of the process is for Resource and Support Surveys (RSS). These surveys are scheduled to take place from January1 – April 30, 2018, so if you see Federal surveyor accompanying State surveyors, don’t be surprised. The pilot is focused on the following areas of concern:
- Abuse and Neglect
- Admission/Transfer/Discharge
- Dementia Care
The Federal surveyors will be focusing on these areas of concern during the RSS surveys for Phase 1, but they will be available to answer any questions that State surveyors may have during the survey process.
Phase 2 of the FOSS pilot will be conducted during the timeframe of May 1 – September 30, 2018. The Phase 2 Surveys will be Focused Comparative Surveys, which are the evaluative component of the FOSS process. These surveys will be conducted by one Federal surveyor within 30 days after completion of an annual recertification or complaint survey. The surveyor will conduct an independent investigation of the identified concern areas by following all investigative protocols and pathways for those areas. A Phase 2 survey sample will be comprised of 60% of the State survey sample of residents that triggered for the above-mentioned concern areas. A 2567 will be issued for any SQC, Harm or IJ citations not identified by the State Agency. Guidance from Appendix Q will be followed if an IJ situation is suspected, but an extended will not need to be completed for any identified SQC.
While there are three identified concern areas being used during this pilot, CMS notes that in future years, each Regional Office (RO) will identify concerns unique to the region in September for the upcoming fiscal year. These areas will be identified by using:
- Nursing Home Compare Quality Measure data
- Quality and Certification Oversight Reports (QCOR)
- Minimum Data Set (MDS) information
For more information, read the January 5, 2018 CMS QSO Admin memo “Revised Federal Oversight Support Survey (FOSS) Process National Pilot.”
Are you preparing for an upcoming survey? CMS Compliance Group’s interdisciplinary consulting team can help you get ready for the new LTCSP with our mock surveys. Contact us to learn more.
