True story: A freestanding ASC I once worked for received an unannounced visit from a state inspector. The receptionist ushered him into an empty office and took his business card to the acting administrator, whose office was right next door. Upon examining the card, the acting administrator - unaware that the inspector was nearby - shouted through her open door, "Good grief, the state is here! Get the doorstops out of the doors!"
Not the best way to begin a survey, was it?
Many of us can recount similar experiences that, miraculously, didn't wind up closing our facilities, even if they did jumpstart our pulses and gray a few hairs. Let's face it: Even prearranged inspection visits from local, state, federal or accrediting authorities can spell stress and anxiety for your entire team.
But here's a secret: Surveyors are human. Like you and me, they're trying to do a good job. They're dedicated to safety and quality. The difference is, a surveyor only has a few hours to gather information and measure compliance before judging a facility's performance. It's a daunting responsibility.
We should match that responsibility by ensuring that the surveyors' jobs are as easy as possible. A facility that is prepared and open to the needs and requests of its surveyor will likely see a more favorable outcome, and may even benefit from a more productive survey. Here are eight ways to impress the surveyors when they visit seeking proof of your commitment to quality.
Whether your survey is expected or unannounced, your team and especially your key leaders should be prepared to provide support and counsel to any surveyor who walks in the door.
Be ready to demonstrate what your facility has done over the past few years, and what it continues to do. Accreditation and licensure are not just a snapshot of a few days or a week or a month of preparation. They encompass an ongoing commitment to quality process and patient care. If evidence of these standards is not readily documented and retrievable, a center's good works may go unnoticed.
That having been said, surveys and inspections are becoming less about paperwork and more about communicating with the staff and observing the day-to-day integration of regulatory requirements. So preparation means more than just managers with reams of paper. It means continually educating your staff and modeling the right way to do things. In that way, doing the right thing for the right reason will become automatic for all staff members.
In addition, the absence of one person shouldn't keep a facility from providing a surveyor with necessary information. (Remember the panic you felt when a surveyor visited while the boss was in the Bahamas?) A facility with a rigid hierarchy may find itself limited if only one or two staff members know where to find documents and requested information. If a facility is truly working as a team, however, this is less likely to occur.
Surveyors may be skilled observers, but a facility that presents its documentation and paperwork in an organized manner makes the surveyor's job much easier.
One way to be more organized is to create a directory grid that lists each standard or requirement alongside the location or source of your documents or substantiation of compliance.
Consider creating administrative and contracts binders to organize important information rather than seeking papers from various files and folders. You can download a sample table of contents at www.outpatientsurgery.net/forms. Not only will this assist your surveyors and show them you mean business about regulations, it will be an enormous administrative help.
Once, for a survey at a newly opened ASC, we had cross-referenced state, federal and accreditation requirements in four binders, one each for administrative, contracts, minutes and policies. The surveyor was so impressed, he asked for copies of the directory grid and tables of contents.
Know the requirements
Consider the surveyor who asks a staff member about a particular subject only to be greeted by a blank stare and "Wow, are we supposed to be doing that?"
No excuses: Regulations and standards are widely published. The facility has committed to them. Accrediting organizations provide multiple forms for clarification. A surgical facility's leaders should know what those standards require.
If your interpretation of certain requirements should differ from that of the surveyor's, it's acceptable to challenge him, but do so respectfully. Don't argue. If you feel that you meet a particular requirement and the surveyor doesn't, explain why you're challenging and provide examples that show how your facility meets the intent of the standard.
Surveyors work hard to be fair and consistent, but they may have biases based on their own work histories. If you're unable to convince a surveyor of your point of view, it's not advisable or even worthwhile to become argumentative. There is a process for disputing survey outcomes that you can pursue after the written report is filed.
If, however, the disputed regulation isn't one that threatens to compromise your licensure, certification or accreditation status, the better plan may be simply acknowledging your differences of opinion, accepting the surveyor's comments and responding with corrective actions.
Learn from the experience
Anyone who's tried to get a one-on-one audience with an expert at a particular agency or organization knows how challenging it can be. View having your very own expert in front of you as a great opportunity for education and discussion, a chance to learn the "why" and "how" of regulations in addition to the "what is required." I've always found surveyors to be enthusiastically willing to share ideas and suggestions, especially when the staff asks questions and shows interest.
Pay attention during survey meetings. Conversations on the side not only disrupt the proceedings, they can negatively influence the surveyor. During any inspection, your staff should be professional and mannerly.
Listen more than you speak. Answer the surveyor's questions thoroughly and ask your own when they're pertinent, but don't keep talk, talk, talk, talking, or you might be perceived as nervous or tedious.
Attitude is everything and, as I mentioned before, surveyors are human. They appreciate being treated with respect and kindness, and smiles go a long way in conveying interest and understanding in what's being said. Can you imagine spending a full day, or several days, in a place where no one smiled or showed any interest in you as a person?
Take pride in your facility
Maintain a clean, neat environment. Words only go so far, but the manner in which you implement your policies and processes says much more. It's obvious to the surveyor whether you care about the cleanliness and upkeep of the facility when he observes its condition. Not only should the floors, walls and equipment be clean, but you should also eliminate messy countertops and drawers. Even though it sounds like a cliche, I've actually seen a state inspector use a glove to check high ledges for dust.
Institute processes that ensure compliance with environmental requirements, whether they involve the changing of air filters or maintaining an electrical generator. An "environmental dashboard" chart or spreadsheet (available for download at www.outpatientsurgery.net/forms) can serve as a month-to-month reminder of duties and renewals as well as a method of documenting compliance with environmental requirements.
Pride in a facility is not only about physical surroundings, though. Positive customer service skills should be evident everywhere the surveyor goes, even if he seems absorbed in a discussion. What's being said? How are patients being talked to? What actions are the staff members taking when they think they aren't being watched? Many surveys now include conversations with visitors and patients. Imagine having a relationship with your patients and visitors that will lead them to tell a surveyor, "I wouldn't have surgery done anywhere else." What better testimonial is there?
Play for the team
Good patient care involves every staff member, from the surgeons and anesthesiologists to the maintenance staff and housekeeping crew. Be sure your entire staff is engaged as a team. You can't fake real teamwork, and if you don't have a cohesive team throughout the year it will show, so foster this crucial quality through good communication, respectful relationships and common goals.
Help all members to prepare for their encounters with surveyors. Forget about last-minute cramming like college students before exams, though. Focus on ongoing education and sharing of information with your staff instead. This will show the surveyor that their preparedness is a year-round trait, not just window dressing for his visit.
Emphasize patient safety
In recent years, patient safety has become perhaps the most publicized issue affecting our industry. It's an issue you must aggressively and comprehensively address every day, for every patient. Being proactive on this front shows a professionalism that is not driven by rules and regulations, but by a genuine concern for the patient. There is no allowance for mediocrity in the eyes of any surveyor on issues relating to patient safety.
JCAHO promotes National Patient Safety Goals and Sentinel Event Alerts, but these two safety mechanisms are applicable to any surgical facility, regardless of accreditation. The implementation of a consistent protocol for patient and operative site identification is an absolute necessity, and every surveyor will be seeking evidence that you're doing it for every patient. If you want to impress your surveyor, it's essential that patient safety stand at the foreground of your clinical care and governing decisions.
Focus on the patient
Surveyors want to observe the entirety of the patient experience, not just the environment, the policies or the documentation that support it.
Patient safety, in terms of sedation, anesthesia and procedure, may be our primary objective, but there is without question more to the patient experience than these clinical concerns. There is also an intangible aspect of our care, the humanity of our service to patients and their families.
While we may perceive this aspect to be one of the niceties of our care, our attention to the confidential, emotional and social needs of our patients will weigh heavily on all surveys, a fact which we must always keep in mind.
The mark of excellence
Providing ambulatory surgery services is a complex business. It requires a dedication to countless demands and details in the service of our patients. That's why inspections are important.
Greet your surveyors with a smile. Eagerly present your centers for their inspection. And treat accreditation as a byproduct of quality patient care. We should desire the scrutiny of regulatory and accrediting agencies and impress them with the way we work. At the end of the day, they - like our patients - are the ones who validate us and the excellence that we're striving for.