margaret huguet, rn long term care supervisor health ...objectives at the end of this session the...
TRANSCRIPT
Margaret Huguet, RN Long Term Care Supervisor Health Standards Section
Objectives At the end of this session the participant will be able
to:
Verbalize an understanding of the purpose and themes of the revised federal requirements for long term care.
Navigate through the requirements with an understanding of format and language changes.
Identify requirements within each of the 3 Implementation Phases;
42 CFR 483 Subpart B
Purpose Emergence of significant innovations in care and
quality assessment
Change in Population
Enhanced knowledge about resident safety, health outcomes, individual choice, and QAPI
Types of Changes Content & Structural
Added new requirements
Strengthened some of the regulatory language
Terminology changes
Eliminated duplicative or unnecessary provisions
Aligned requirements with current clinical practice standards
Reorganizing the regulations as appropriate
Themes in the final rule Person-Centered Care
Staffing & Competency
Quality of Life and Care
Changing Population
Implementation of Legislation
Alignment with Health & Human Services (HHS) Initiatives
Nursing Service
Food & Nutrition
Activities
Social Services
Medical Care
Medication Management
F279 - §483.21(b) Comprehensive Care Plans
(1) The facility must develop and implement a comprehensive person-centered care plan for each resident, consistent with the resident rights set forth at §483.10(c)(2)and §483.10(c)(3)…
Person Centered Care
F280 - §483.10(c)(2) Comprehensive Care Plans - Resident Rights The right to:
Participate in the development and implementation of person-centered plan of care
Participate in the planning process,
Identify individuals or roles to be included in the planning process,
Request meetings
Request revisions to the person-centered plan of care.
Participate in establishing the expected goals and outcomes of care, the type, amount, frequency, and duration of care, and any other factors related to the effectiveness of the plan of care.
Receive the services and/or items included in the plan of care.
See the care plan,
Right to sign after significant changes to the plan of care.
Person Centered Care
F248 - §483.24(c) Activities. Provide an ongoing program to support residents in
their choice of activities, both facility-sponsored group and
individual activities and
independent activities,
to meet the interests of and support well-being,
encouraging independence and interaction in the community.
Person Centered Care
F360 - §483.60 Food and nutrition services.
a nourishing, palatable, well-balanced diet
that meets his or her daily nutritional and special dietary needs,
taking into consideration the preferences of each resident.
Person Centered Care
F490 – Administration §483.70(e) Facility assessment
Phase 2 Implementation
The facility must conduct and document
a FACILITY-WIDE ASSESSMENT
to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies.
review and update:
as necessary,
at least annually
Staffing & Competency
Facility Assessment Resident Population Facilities Resources
Number/ facility’s resident capacity
Care required
Staff competencies necessary
Physical environments, equipment, services, other…
Ethnic, cultural, religious factors…
Buildings/structures/vehicles
Equipment
Services provided
Personnel
Contracts/MOUs/…
Health information technology resources
Staffing & Competency
F353 - §483.35 Nursing Services Sufficient nursing staff
with the appropriate competencies and skills sets
to assure resident safety and attain or maintain the highest practicable well-being,
as determined by resident assessments and individual plans of care and
considering the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment required at §483.70(e).
[As linked to Facility Assessment, §483.70(e), will be implemented beginning November 28, 2017 (Phase 2)]
Staffing & Competency
F361: §483.60 (a) Staffing – Food & Nutrition Sufficient Staff
with the appropriate competencies and skills sets
to carry out the functions of the food and nutrition service,
taking into consideration resident assessments, individual plans of care and the number, acuity and diagnoses of the facility’s resident population
In accordance with the facility assessment required at §483.70(e) [As linked to Facility Assessment, §483.70(e), will be implemented beginning November 28, 2017 (Phase 2)]
Staffing & Competency
F490 - Administration §483.95 Training Requirements Phase 3 Implementation A facility must:
develop, implement, and maintain an effective training program for all new and existing staff; individuals providing services under a
contractual arrangement; and volunteers, consistent with their expected roles.
determine the amount and types of training necessary based on a facility assessment as specified at §483.70(e).
Training topics include: communication, resident’s rights and facility responsibilities, QAPI, Infection Control, Compliance and ethics, Behavioral health
Staffing & Competency
F498 §483.95(g)(3) Required in-service training for nurse aides Phase 3 Implementation
Address areas of weakness as determined in nurse aides' performance reviews and facility assessment at § 483.70(e) and may address the special needs of residents as determined by the facility staff.
Staffing & Competency
As linked to Facility Assessment F319 – Behavioral Health Services
F353 - Nursing Services
F361 – Food and Nutrition Services
F441 - Infection prevention and control program
F490 – Administration
F498 – Proficiency of nurse aides
F520 – QAPI
QOL and QOC are overarching principles in the delivery of care to residents of nursing homes and should be applied to every service provided.
Quality of Life and Care Treatment, care, and services
are provided:
consistent with the comprehensive resident assessment
in accordance with professional standards of practice
following the comprehensive person-centered care plan
that is consistent with resident’s needs and choices
Quality of Life and Care
Trauma-informed care
Behavioral health services
F319 – §483.25(m) Trauma-informed care Phase 3 Implementation
The facility must ensure that residents who are trauma survivors receive
culturally competent, trauma-informed care
in accordance with professional standards of practice and
accounting for residents’ experiences and preferences
in order to eliminate or mitigate triggers that may cause re-traumatization of the resident.
Changing Population
Resources Person-centered care that reflects the principles set forth
in the SAMSHA’s
“Concept of Trauma and Guidance for a Trauma-Informed Approach,”
http://store.samhsa.gov/shin/content/SMA14-4884/SMA14-4884.pdf
SAMSHA = Substance Abuse and Mental Health Services Administrations
Changing Population
F319 - §483.40 Behavioral health services. Phase 2 Implementation
Behavioral health care and services
to attain or maintain the highest practicable well-being,
encompasses a resident’s whole emotional and mental well-being,
includes, not limited to, the prevention and treatment of mental and substance use disorders.
Changing Population
F319 483.40(a) Behavioral health services. Phase 2 Implementation
The facility must have:
sufficient staff who provide direct services
appropriate competencies and skills sets
assure resident safety and attain or maintain the highest practicable well-being
considering number, acuity and diagnoses of the facility’s resident population in accordance with §483.70(e).
Changing Population
F319 – Behavioral health services Competencies and skills sets include, but are not limited
to, knowledge of and appropriate training and supervision for:
Phase 3 Implementation 483.40(a)(1) Caring for residents with
mental and psychosocial disorders, a history of trauma and/or post-traumatic stress disorder
Phase 2 Implementation
483.40(a)(2) Implementing non-pharmacological interventions
Changing Population
F319 – Behavioral health services §483.40(b) Based on the comprehensive assessment of a
resident, the facility must ensure that—
§483.40(b)(1) A resident who displays or is diagnosed with mental disorder
or psychosocial adjustment difficulty, or who has a history of trauma and/or post-traumatic stress disorder, receives appropriate treatment and services to correct the assessed problem or to attain the highest practicable mental and psychosocial well-being.
(as linked to history of trauma and/or post- traumatic stress disorder, will be implemented beginning November 28, 2019);
Changing Population
AFFORDABLE CARE ACT IMPACT ACT
F490 -Compliance and Ethics §483.85(b) General rule.
Phase 3 Implementation
The operating organization for each facility must have in operation
a compliance and ethics program (as defined in paragraph (a) of this section)
that meets the requirements of this section.
Implementation Legislation
Compliance and Ethics Program Basic Elements:
Designation of a compliance officer and compliance committee
Development of compliance policies and procedures, including standards of conduct
Development of open lines of communication
Appropriate training and teaching
Internal monitoring and auditing
Response to detected deficiencies
Enforcement of disciplinary standards
Implementation Legislation
Resources DHHS Office of the Inspector General (OIG) has
issued industry-specific guidance documents on compliance.
March 16, 2000 Federal Register (65 FR 14289)“Final Compliance Program Guidance for Nursing Facilities”
September 30, 2008 Federal Register (73FR 56832) “OIG Supplemental Compliance Program Guidance for Nursing Facilities”
Implementation Legislation
QAPI
initiative
Implementation Legislation
F520 – §483.75 Quality Assurance Performance Improvement Program develop, implement, and maintain
effective, comprehensive, data-driven QAPI program
focuses on indicators of the outcomes of care and quality of life
Phase 2 Implementation - (a)(2) Present its QAPI plan to the State Survey Agency no later than 1 year after the promulgation of this regulation;
Phase 3 Implementation for all other subparts of 483.75
Implementation Legislation
§483.75(g) Quality Assessment and Assurance Phase 1 Implementation
(1) A facility must maintain a quality assessment and assurance committee consisting at a minimum of:
(i) The director of nursing services;
(ii) The Medical Director or his/her designee;
(iii) At least three other members of the facility's staff, at least one of who must be the administrator, owner, a board member or other individual in a leadership role;
Quality Insights QIN-QIO: Free Assistance The Quality Improvement Organization Quality Innovation Network for
Louisiana
They offer free assistance for your performance improvement projects (PIPs), QAPI, free webinars, toolkits, individual data reports, and so much more
QAPI assistance includes how to document your PIP within the methods recommended by CMS QAPI at Glance document
To get started today, reach out to:
Julie Kueker
218-294-0458
CMS QAPI Resources: https://www.cms.gov/Medicare/Provider-enrollment-and-Certification/QAPI/nhqapi.html
Quality Insights: www.qualityinsights.org
Reporting reasonable suspicion
of crimes
Implementation Legislation
F225 - §483.12(b) Freedom from Abuse, Neglect, Exploitation
Implementation Phase 2
Develop and implement written P/P’s that:
(4) Ensure reporting of crimes occurring in federally-funded LTC facilities
in accordance with section 1150B of the Social Security Act.
Implementation Legislation
(i) Annually notifying COVERED INDIVIDUALS of reporting requirements.
(A) report to the SA and one or more law enforcement …
any reasonable suspicion of a crime against any individual who
is a resident of, or is receiving care from, the facility.
(B) report not later than 2 hours after forming the suspicion, if the events that cause the suspicion result in serious bodily injury, or
not later than 24 hours if the events that cause the suspicion do not result in serious bodily injury.
(ii) Posting a conspicuous notice of employee rights, as defined at section 1150B(d)(3) of the Act.
(iii) Prohibiting and preventing retaliation, as defined at section 1150B(d)(1) and (2) of the Act.
Implementation Legislation
F225 - §483.12(c) Freedom from Abuse, Neglect, Exploitation Phase 1 Implementation
§483.12(c)(1) Ensure that all alleged violations involving abuse, neglect, exploitation, or mistreatment, including injuries of unknown source and misappropriation of resident property, are: Reported immediately, but not later than: 2 hours after allegation is made, if the events that cause the allegation
involve abuse or results in serious bodily injury,
or not later than 24 hours if the events that cause the allegation
do not involve abuse and do not result in serious bodily injury to the administrator and to State Survey Agency
TRAINING Care for
residents with
Dementia and
Abuse Prevention
Implementation Legislation
Dementia and Abuse Training F498 §483.95(g) Required
in-service training for nurse aides. In-service training must—
§483.95(g)(1) Be sufficient to ensure the continuing competence of nurse aides, but must be no less than 12 hours per year.
§483.95(g)(2) Include dementia management training and resident abuse prevention training
F226 - §483.95(c) Abuse, neglect, and exploitation. In addition to the freedom
from abuse, neglect, and exploitation requirements in § 483.12, facilities must also provide training to their staff that at a minimum educates staff on—
§483.95(c)(3) Dementia management and resident abuse prevention.
Implementation Legislation
http://innovation.cms.gov/initiatives/rahnfr/index.html
HHS Priorities
F441 §483.80 Infection Control The facility must establish and maintain an infection
prevention and control program designed to provide a safe, sanitary and comfortable environment and to help prevent the development and transmission of communicable diseases and infections.
HHS Priorities
F441 - §483.80 Infection Control Develop Infection Prevent and Control Program
(IPCP)
Antibiotic Stewardship Program -Phase 2 Implementation
Designate at least one Infection Preventionist (IP) - Phase 3 Implementation
Written policies and procedures for the IPCP
Education or training r/t the ICP
Integration of the ICP with the facility’s QAPI processes
HHS Priorities
Antibiotic Stewardship Program Phase 2 Implementation
includes antibiotic use protocols and
a system to monitor antibiotic use.
HHS Priorities
Infection Preventionist Phase 3 Implementation
The IP must:
have primary professional training in nursing, medical technology, microbiology, epidemiology, or other related field;
be qualified by education, training, experience or certification;
work at least part-time at the facility; and
have completed specialized training in infection prevention and control.
HHS Priorities
Health Associated Infections “National Action Plan to Prevent HAIs.”
http://www.hhs.gov/ash/initiatives/hai/actionplan/
HHS Priorities
F329 - §483.45(e) Psychotropic Drugs §483.45(e)(1)-(5) Phase 2 Implementation
Based on a comprehensive assessment of a resident, the facility must ensure that-- (1) Residents who have not used psychotropic drugs are
not given these drugs unless the medication is necessary to treat a specific condition as diagnosed and documented in the clinical record;
(2) Residents who use psychotropic drugs receive gradual dose reductions, and behavioral interventions, unless clinically contraindicated, in an effort to discontinue these drugs;
HHS Priorities
Psychotropic drugs Defined as:
any drug that affects brain activities associated with mental processes and behavior.
These drugs include, but are not limited to, drugs in the
following categories: (1) anti-psychotic, (2) antidepressant, (3) anti-anxiety, (4) hypnotic, (5) opioid analgesic, and (6) any other drug that results in effects similar to the drugs listed
above.
HHS Priorities
F329 - §483.45(e) Psychotropic Drugs Phase 2 Implementation
(3) Residents do not receive psychotropic drugs pursuant to a PRN order unless that medication is necessary to treat a diagnosed specific condition that is documented in the clinical record; and
(4) PRN orders for psychotropic drugs limited to 14 days Except , physician/prescribing practitioner believes appropriate for
the PRN order to be extended beyond 14 days, document rationale medical record and indicate the duration.
(5) PRN orders for anti-psychotic drugs
limited to 14 days cannot be renewed unless the attending physician or prescribing
practitioner evaluates the resident for the appropriateness of that medication.
HHS Priorities
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Red Italics = New
Regulatory Language
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Section §483.10 Resident Rights Retaining all existing resident rights;
Additions to P/P’s may be needed;
Updated language and organization to:
Improve logical order and readability,
clarify aspects of the regulation, and
include advances such as electronic communications.
Navigating Through
Section §483.12 Freedom from Abuse, Neglect, and Exploitation Additional definitions
New Section within CFR
Strengthened existing protections
Additions needed to P/P’s
Adds language r/t right to free from neglect and exploitation
Inclusion of Reporting of reasonable suspicion of a crime in Phase 2
Will require QAPI aspect in Phase 3
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Comprehensive Care Plan- Baseline Care Plan Phase 2 Implementation
develop and implement within 48 hours of admission
include instructions needed to provide effective and person-centered care
Initial goals based on admission orders
Physician orders
Dietary orders
Therapy services
Social services
PASARR recommendations, if applicable
comprehensive care plans developed in 48 hrs. can take place of
Provide resident/representative with summary of baseline care plan
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Comprehensive Person-Centered Care Planning F279 – 483.21 (b) Care Plan must include any specialized
services the facility will provide based on PASARR recommendations
F280 - §483.21(b)(ii)(c) - Nurse aide with responsibility for the resident and §483.21(b)(ii)(d) member of food and nutrition as part of ID Team/Care planning;
F284 - §483.21(c)(1) Develop & implement discharge planning process
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F361 Food and nutrition services §483.60(a)(1) Qualified Dietitian or other qualified
nutrition professional
§483.60(a)(2) If not employed full time, the facility must designate a person to serve as
Director of food and nutrition services
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F411 – §483.55 Dental Services Dentures Phase 2 Implementation
Have policy identifying circumstances when loss or damage of dentures is the facility’s responsibility and may not charge a resident for the loss or damage
Promptly, within 3 days, refer residents with lost or damaged dentures for dental services.
If referral not done, provide documentation of what did to ensure the resident could still eat and drink adequately while awaiting dental services and the extenuating circumstances that led to the delay.
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F428 483.45 c - Drug Regimen Review Reviewed every month
include a review of the resident’s medical chart (phase 2)
Pharmacist must report any irregularities to the attending physician, medical director, and director of nursing, and these must be acted upon.
Develop and maintain P/Ps for monthly drug regimen review Time frames for different steps in the process and steps the
pharmacist must take when identifying and irregularity that requires urgent action to protect resident
F323 483.25(n) – Accidents Bed Rails Attempt appropriate alternatives prior to installing a
side or bed rail
Ensure correct installation, use, and maintenance of bed (1) Assess risk of entrapment prior to installation
(2) Review risks and benefits with resident or RP obtain informed consent prior to installation.
(3) Ensure bed’s dimensions are appropriate for the resident’s size and weight.
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F461 –§483.90(c)(3) Physical Environment - Bed Rails Conduct regular inspection of all bed frames,
mattresses, and bed rails, if any, as part of a regular maintenance program
When bed rails and mattresses are used and purchased separately from the bed frame, ensure bed rails, mattress, and bed frame are compatible.
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F465 – 483.90(h)(5) Other Environmental Conditions Establish policies, in accordance with applicable
Federal, State, and local laws and regulations, regarding smoking, smoking areas, and smoking safety that also take into account non-smoking residents.
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Terminology changes Examples Examples
F314
Pressure Sores
Pressure Ulcers
F315
Urinary Incontinence
Incontinence (both fecal and urinary)
F317 & F318
Range of Motion
Mobility
F322 483.25 (g) Naso-Gastric Tubes
Assisted nutrition and hydration
F325 Nutrition
Assisted nutrition and hydration
F360 Dietary Services
Food and nutrition services
Navigating Through
New Tags F525 §483.70(n)(1)(2)
Binding arbitration agreements
F526 §483.70(o)(1)-(4)
Hospice services
F527 §483.70(q)(1)-(5)
Mandatory submission of staffing information based on payroll data in a uniform format.
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Implementation Dates
Phase 1 must be implemented by November 28, 2016.
Phase 2 must be implemented by November 28, 2017.
Phase 3 must be implemented by November 28, 2019.
Phase 1 Implementation Existing requirements, those requirements relatively
straightforward to implement, and require minor changes to survey process.
New regulatory language added to the existing F-tags
CFR numbering changes
Phase 2 Implementation F-tag renumbering
additional effective regulations
additional interpretive guidance.
Phase 2 Implementation F156 - Information and
Communication
F202 –Transfer & Discharge Documentation
F225 – P/Ps for Reporting of Crimes
F279 - Baseline Care Plans
F309 - Dementia
F319 Behavioral health services
F328 - Prostheses
F329 - Psychotropic drugs
F353 & F361 as it r/t’s Facility Assessment
Phase 2 Implementation F411 - Dentures
F428 – DRR – Pharmacist review of medical chart
F441 - Antibiotic Stewardship Program
F490 - Facility assessment
F520 - QAPI to SSA
Phase 3 Implementation
Phase 3 Implementation F226 Abuse P/Ps – QAPI
aspect
F282 Care Plans – be culturally competent and trauma-informed
F319 Trauma-informed care
F441 -Infection Preventionist & QAPI team member
F463 - Resident Call System – each resident’s bedside
F490 - Compliance and ethics program
F490 - Training Requirements
F493 - Governing body – responsible/accountable for QAPI program
F498 - In-service training for NA’s – address areas of weakness identified in the facility assessment
F520 – QAPI
Quality Indicator Survey/ Traditional Survey
New Survey Process Quality Indicator Survey
+
Traditional Survey Process
+
Revised Regulations
Louisiana Top 10 Deficiencies 1. F282 – Follow Plan of
Care
2. F441 – Infection Control
3. F323 – Accidents/ Supervision
4. F371 – Food Store/Prepare/Serve
5. F157 – Notification of Change
6. F278 – Accuracy of Assessment
7. F280 – Revise Care Plan
8. F309 – Highest Practical Well Being
9. F431 – Drug Storage
10. F253 - Housekeeping
Top tags cited at Harm Level F157 – Notification of
Change
F223 - Abuse
F282 – Follow Plan of Care
F309 – Highest Practicable Well-being
F314 – Pressure Ulcers
F315 – Weight Loss
F323 – Accidents Supervision
F325 – Weight Loss
F327 – Sufficient Fluids
F353 – Nurse Staffing
F490 - Administration
F502 – Laboratory Services
F520 - QAA
Tags Cited at Immediate Jeopardy Health Survey LSC Survey
F323 – Accident / Supervision
F490 – Administration
K343 – Fire Alarm System – Notification
K353 – Sprinkler System – Maintenance and Testing
K915 – Electrical Systems