Monday, February 16, 2015

Vision, Hearing and W323

W323 specifically deals with Vision and Hearing screenings.  These screenings are required annually and to date have been completed by a variety of screeners.  Audiologist, optometrist, and even physicians have completed these assessments to comply with the federal standards.

In Texas it has been generally accepted that if your physician checks hearing and vision and notes that it is "Okay" or "Within normal limits" etc, surveyors have stayed away from writing W323.  Often this has been completed by simply a "check" next to "Hearing," and/or "Vision".   These "checks" or "checkmarks" have been accepted in most survey regions of Texas for upward of twenty years now.  That has recently changed apparently.

At a recent survey a surveyor noted that a "check" was not sufficient to indicate what sort of hearing and vision screening a physician had completed.   It did not seem to matter that the choices for the check were "Normal," "Abnormal," and "Unable to determine".  For the survey in question, "Normal" was checked for each individual questioned; however, that did not seem to meet the needs.  The surveyor stated, "CMS has indicated that a checkmark is no longer acceptable and that we have to cite deficient practice for a checkmark."  That statement was repeated again in the exit survey.

Interestingly, the standard did not change and neither did the information found in the federal tag regarding practices and probes.  Apparently, someone working at CMS changed his or her opinion about what is and is not acceptable and issued some sort of memo to the states, or at least the state of Texas.

The particular facility in question had about five years worth of physicals on file at the home.  I looked back through them and each had the same use of a "checkmark" for a review of vision and hearing.  It appeared to support what I hear from many QIDP's and Administrators and that is that "Surveyors will find something no matter how good your program is doing."  Ironically, none of the individuals with checkmarks have hearing devices or glasses.  The individuals who have glasses in that home see an optometrist on a regular basis.

In the end the facility will have one of three choices.  It can naturally appeal the decision of the surveyor in an attempt to find out if this was simple surveyor bias or if it has a foundation in the CMS oversight.  The facility could simply start having everyone see an optometrist and audiologist regardless of needs and thus spend further Medicaid tax dollars.  Finally, the facility could request additional information from the physician regarding specific test used to determine that everything "checks" out for an individual, and that could simply cause the physician to refer the individual to someone else.  Whatever choice the facility makes, one thing is clear and that is that standards continue to be open to interruption whether its by an individual surveyor, a region, or even the federal government.  

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