Posted by: Robert Markette
May 10, 2006

I have been dealing with a number of issues resulting from surveys lately and I can’t help but make a few comments.  This may seem obvious to you, but I keep seeing these things cause providers problems and so I feel the need to repet myself.

First, it never ceases to amaze me how surveyors miss documents in a clinical or employee file.  I understand form talking to surveyors that part of the problem is that every home health agency does things slightly different.  This creates an issue for surveyors who do not know your files the way you do.  One thing that can assist surveyors greatly is trying to make it obvious what is in the file. 

For example, you are required to have criminal histories for employees.  The location of these items in the employee file should be noted so that it is obvious to the surveyor were to look.  If you are cited for failing to have this documentation, you can engage in the informal dispute resolution process (In Indiana) and usually have the tag removed.  However, if IDR is not an option or is unsuccessful, you are stuck with a tag that you do not really deserve.  It is far easier to make these items obvious than to fight an incorrect tag later.   

Another issue that keeps popping up is surveyor confusion resulting from the use of incorrect terminology.  For agencies that offer both skilled and unskilled (homemaker/companion/attendant) care this is an even bigger issue.  Many a home health aide or attendant has noted in the client’s file that he “administered” medication.  When, in fact, he simply reminded or assisted the patient with the medication.  By writing administered in the record, the employee has created a problem for you come survey time. 

You should train your employees regarding terminology, especially for your non-skilled employees such as homemakers and companions.In states such as Indiana, where agencies are licensed and where State law differentiates between home health care and personal services, errors in terminology can lead to other problems.  Personal services licensure statutes have been passed or are being passed in a number of states. 

These statutes govern the provision of unskilled home care such as companion, homemaker, and attendant services.  Because they are non-medical services, they often have less restrictive standards.Agencies that offer both types of services need to be careful not only that the non-skilled employees use the correct terminology assisted with bath, not bathed, etc, but also that the files are kept separate.  Misuse of terminology or intermingled files can lead a surveyor to site your agency for a violation of the home health COPs or licensure regs., because the surveyor mistakenly reviews a personal care file as a home health file. The personal care file is maintained according to a different set of standards which will result in citations.

In Indiana, the state has indicated that agencies offering both types of service should keep the files strictly segregated and during a home health licensure/certification survey they should only produce the home health files unless the surveyor specifically asks for personal care files as well.  This avoids confusion for the surveyor.

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