SEIU Local 1199WI

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Proposed Audit of Nursing Home Surveying

Testimony of Robert Kraig, Ph.D.
Political Director, SEIU Wisconsin State Council

Joint Audit Committee
October 3, 2001

As the largest union of nursing home workers in the state, and as the collective bargaining representative for most nursing home surveyors in Wisconsin, we hear a great deal about the shortcomings of the surveying system from both sides of the issue. We therefore strongly support this proposed audit, and respectfully suggest the following avenues of investigation:

(1) Non-managerial nursing home workers are universally critical of the survey process. They believe that inspections are not a surprise to management, and that facilities are much better staffed on the days state is in the building than any other time of the year. We consistently hear reports from our members that cast into doubt the efficacy of the survey system. The proposed audit should explore whether surveyors receive an accurate picture of the day-to-day operation of facilities. We would be happy to provide nurse aides for auditors to interview on this issue.

(2) Many surveyors believe that the process for filing citations is too bureaucratic and time consuming. As a result, when there are serious violations in a facility, surveyors do not have the time to file mid-level citations. Better staffing that reflects the increased acuity of nursing home residents, and a streamlined process for filing and processing citations, would create a more consistent surveying system.

(3) The audit should explore the relationship between the outdated Wisconsin nursing home staffing standard--which is 2.5 hours per resident day for most nursing home residents--and the efficacy of the survey system. It is very difficult under this system for surveyors to determine whether a facility is adequately staffed. Most independent experts believe that states should shift to an easier to enforce staffing ratio system, that requires a specific number of caregivers per resident. Because staffing is the key variable to quality care, a standard that could be easily assessed by surveyors would better guarantee a consistent level of care in Wisconsin nursing homes.

(4) Acuity increases in nursing homes and assisted living facilities suggest that the survey system should be augmented in both sectors. Nursing home residents are sicker than ever before, and levels of acuity that used to be commonplace in nursing homes are now served by assisted living facilities. The audit should consider whether or not the nursing home survey system, including the use of surveyors with medical backgrounds, should be extended to assisted living facilities.