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 The QIS Expert: Can QIS Methods Help Providers Comply With QAPI’s Systematic Analysis And Action Regs?

 

 

This is the final column in A series of five addressing how QIS methods can be used for Quality Assurance & Performance Improvement (QAPI). The previous four columns (in February, April, June, and August 2013 issues) have shown the parallels between QIS methods and the first four of the Five Elements of QAPI.

These first four columns showed that QIS is consistent with where the Centers for Medicare & Medicaid Services is heading on QAPI from a regulatory standpoint. More importantly, QAPI is a voluntary means to continuously improve care. (See www.cms.gov/Medicare/ Provider-Enrollment-and-Certification/Survey CertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-05.pdf).

Element 5: Systematic Analysis and Systemic Action provides the framework that providers can use to voluntarily conduct QAPI. 

CMS says that Systematic Analysis involves the following: “The facility uses a systematic approach to determine when in-depth analysis is needed to fully understand the problem, its causes, and implications of a change. The facility uses a thorough and highly organized/structured approach to determine whether and how identified problems may be caused or exacerbated by the way care and services are organized or delivered.”

Just as surveyors use the multifaceted Stage 1 investigation of the QIS process to determine when in-depth analysis is needed, providers can use those same assessments, but with a different type of reporting. “Understanding the problem, the causes, and the implications for change” involves drilling deeper into the QIS data than is required for the survey process.

For example, it is not sufficient for QAPI to determine that a resident’s preferences are not being honored by staff. Instead, staff must understand specifically what choices are not being honored; whether it is just a single resident, a unit, or the facility as a whole; and what must be done to improve accommodation of resident preferences.

Thus, provider QAPI systems that use QIS methods must go beyond the work of surveyors in Stage 1. Staff must go beyond the typical questions on resident satisfaction surveys. Fortunately, the QIS questions can provide much of the necessary drill-down when broken down and structured in a QAPI tool.

Element 5 also says that, “Systemic Actions look comprehensively across all involved systems to prevent future events and promote sustained improvement. This element includes a focus on continual learning and continuous improvement.”

Once again, QIS contains tools, when properly restructured, that take aspects of the surveyor investigation process and “look comprehensively across all systems.” This involves advancing the investigation that surveyors conduct a step further—to correcting system failures that are identified. It also requires that providers do not use the QIS methods in a “mock survey” or external consulting model; rather, they use the methods continuously for “learning and continuous improvement.”

In recent years, working with providers, I have observed numerous examples of staff using these QIS tools for QAPI with extraordinary success. So what are you waiting for?

Andy Kramer, MD, is a long term care researcher and professor of medicine who was instrumental in the design and development of the Quality Indicator Survey (QIS).
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