Over the past year or so I’ve noticed (as have many other NCQA surveyors) that the quality of survey preparation has diminished. The reason for this trend is unclear but it is unmistakable.
Good survey preparation should make it easy for the surveyors to assess compliance. I don’t mean to say that it should be easy for the surveyors just to be easy. It should be easy so that you get the best possible score. If a surveyor cannot see evidence of compliance, the score will suffer.
Organizations have a limited number of opportunities to demonstrate compliance. If you don’t “take your best shot” at demonstrating compliance at the initial submission, you’ll waste one of these few opportunities for providing evidence of compliance as you struggle to pull together evidence that should have been submitted initially with the Interactive Survey System (ISS).
Good survey preparation involves several steps:
- Understand the specific requirements of the standard.
- Understand the required evidence of compliance.
- Use support text to tell the story.
- Submit the right evidence.
- Submit the right amount of evidence.
- Highlight and annotate relevant portions of documents.
To understand the requirements of the standard, you need to study the manual—especially the “Explanation” section. For example, Health Plan standard UM 7A states: “The organization notifies practitioners about…[t]he organization’s policy for making an appropriate practitioner reviewer available to discuss any UM denial decision [emphasis added].” However, the Explanation says: “This element applies only to UM medical necessity denial decisions, including pharmaceutical denials.” The language of the standard would lead you to believe that all denials are covered but the explanation indicates that only medical necessity denial decisions are covered.
In this example, you also need to know NCQA’s definition of a medical necessity denial since it is very specific and different from definitions commonly is use in the field. For this, you need to review the Glossary.
Remember that NCQA changes and clarifies standards on an ongoing basis. In addition to reviewing the manual, you need to review the “Questions, Clarifications and Policy Changes” document that comes out periodically. You also need to review the FAQs. If you are using the Survey Tool section of the ISS, the revisions described in the Questions, Clarifications and Policy Changes document will be integrated into the text as of the effective date. This is not true for FAQs! Even if you are using the ISS, you need to check the FAQs on a regular basis. [Please note that the ISS has a PDF version of the manual in addition to the Survey Tool. The PDF file is NOT updated with the Questions, Clarifications and Policy Changes, just the Survey Tool.]
In subsequent entries I’ll discuss the other components of survey preparation.
