Infection Control Survey Visits in Texas

Recently many private providers are reporting infection control surveys in Texas.  These surveys are happening in the middle of the COVID-19 Pandemic. It's a time when providers are trying to safeguard the people living in the ICF/IID system.  Unfortunately, some of the surveys are causing discomfort for providers and the surveyors themselves. 

First, let's look at the basic facts- The ICF/IID program was not around during the last major Pandemic of this proportion - 1918-1920.  In fact, many of the agencies we have today providing regulations and oversight were not around during the Spanish Flu of 1918-1920, and indeed, we have no staff with experience from that Pandemic.   So it must be kept in mind that providers, state and private, HHSC, and CMS is really treading into new territory.  With any move into new territory, there is always a learning period.  There is also a lot of "helpful" opinions floating around.  There are naturally people on all sides of the ICF/IID world with strong feelings as to how this Pandemic should be monitored, handled, and what specific responses are needed.  Because there are so many different views, we are going to see things happen that we agree with and some that we do not agree with happening on all levels.  Let's face it, some providers have no idea what they are doing right now, and some oversight would likely be helpful.  Some providers have extensive systems in place that includes temperature checks, no visitors, and even questionnaires before staff can enter the home.   Other homes are depending on staff to be open and say, "Hey, I'm sick," and that's all they are doing.  Needless to say, as with all disasters, we are all learning.  The bottom line, there are people on all levels with no real experience or knowledge, so we have to learn as we go.

The second thing we must keep in mind is that CMS is directing HHSC to do these survey visits.  In almost all visits I have heard about or reviewed, the surveyors have been professional, apologetic, and fast in their tours.  Just to be truthful, they do not want to be in the home just as the home providers do not want them there.  Nobody wants to be potentially exposed to this virus.  Some surveyors are even apologizing to the homes and saying they understand and wish they did not have to come out right now.  But, we have to keep in mind that standards - federal and state as well as the new E tags for just such disasters - are in place as a minimal procedure to keep the people we serve safe.  We also have to keep in mind that all facilities make mistakes - if they did not, then we would see deficiency-free regular surveys yearly!  But, because we all make mistakes, surveyors need to come into the homes and monitor, point out the errors according to regulations, and allow us time to put corrective measures in place.  That is precisely what is happening now- surveyors are coming out to review and ensure that we - the providers- are doing everything possible to safeguard the people we serve.  Let's face it, sometimes things are overlooked, forgotten, and sadly by some providers simply ignored.  That is the primary reason we need an outside set of eyes to come in and review, point out those concerns, and when necessary, write deficient practice so we can correct and improve our services.  This period is no different - it's all about ensuring the safety and well-being of the people we serve in the ICF programs.  For that alone, we should accept the fact that surveyors need to touch base with us and view the plans right now. 

So far, typical Infection Control Surveys have been reported to focus on Infection Control policies of the home, supplies in the house, PPE in the home, procedures, and training with staff on handwashing, visitor procedures, and community access policies or procedures during this time.   They have also questioned staff ratio plans, how the facility will handle a potential staff having COVID-19, and if the facility is following reporting requirements. Surveyors are asking how the facility is handling informing the people served about the Pandemic - i.e., why are you not going to the workshop, why are you not all going to Walmart, why can you not have visitors right now, etc.? 

It can undoubtedly be frustrating for a facility that has taken safeguards and steps to ensure the protection of the people served to have a surveyor walk up to the door.  The general feeling that seems to be shared is, "We have limited visitors and outings and have no outside contact, and here comes a surveyor with a potential to spread this virus from home-to-home in the front door!"  It's a valid concern, but unfortunately, it is a need.  Just as we have to depend on staff to come and go from the facility, administration, nurses, QIDPs, etc., we also have to expect that surveyors will need to check on our status.  It is not an intent to spread COVID-19, and there is no conspiracy going on to undermine procedures put in place.  All surveyors so far seem to be following whatever access procedures the home has in place - which may include temperature checks, questions about travel, and even some are requesting the surveyor wear a mask.  So, the facility needs to view the surveyor as just another "essential" staff person entering the home just as we would all the other people needed to keep the house functional.  We must always remember, the safety and well-being of the people we serve in these homes must be the priority, and I personally think that is precisely the priority of CMS and HHSC with these Infection Control Surveys.