Follow these 3 steps to insure yourself against survey citations. Now that the Centers for Medicare & Medicaid Services has lifted its prohibition on so-called home health agency "drop sites," many HHAs are breathing easier. But that relaxed attitude could land you in hot water come survey time.
Last summer, CMS said in an Open Door Forum that it didn't authorize drop sites, otherwise known as workstations, way stations, convenience sites or satellites. But in a November 2004 memo to surveyors, CMS spelled out that drop sites are OK under certain circumstances (see Eli's HCW, Vol. XIII, No. 42, p. 330).
In a survey conducted by the National Association for Home Care & Hospice, HHAs in 21 states said they use drop sites to conduct daily business. Agencies use the sites for communication with other clinicians; picking up and dropping off supplies and records; accessing desks, telephones, fax machines and computers; and uploading and downloading computerized records, NAHC says. Be On the Defensive Agencies should be very careful with any drop sites they operate, advises consultant Pam Warmack with Clinic Connections in Ruston, LA. "The surveyors I have encountered are very, very unhappy with 'drop sites' even being an option," Warmack warns.
Many states don't recognize or define drop sites within regulation. Surveyors "view them as an imposition on their already overtaxed survey burdens," Warmack tells Eli.
To head off a deficiency from a hostile surveyor, Warmack recommends taking these steps: Put it in writing. "Define in policy exactly what [your] drop site is and how it does not function in any way, shape or form as a branch," Warmack advises. Prove a negative. Agencies "must prove that no patient care coordination is conducted from the drop site," she urges. Be ready to back up your assertion with cold hard evidence for the surveyor. Observe memo prohibitions. CMS spells out specific no-nos for drop sites in its Nov. 12 memo - make sure you are observing them strictly. "No referrals should be taken, no patient calls received or made, and no representation to the public that the location is associated with the provider," Warmack stresses. Also, no staff should be assigned to the location, CMS says. Warmack advises taking a conservative line rather than risking your compliance record. "View the drop site as a large mail box designed only for convenience in dropping off documentation for a runner to pick up and transport, in a timely manner, to the provider," she counsels.
Editor's Note: The CMS drop site memo is at
www.cms.hhs.gov/medicaid/survey-cert/sc0507.pdf.
