Survey and Regulatory Update - PowerPoint PPT Presentation

Loading...

PPT – Survey and Regulatory Update PowerPoint presentation | free to view - id: 4bde9-ZDc1Z



Loading


The Adobe Flash plugin is needed to view this content

Get the plugin now

View by Category
About This Presentation
Title:

Survey and Regulatory Update

Description:

F371 Sanitary Conditions. F309 Highest Practicable Well-Being. F281 Professional standards ... F371 Sanitary Conditions. Merged F370 and F371 ... – PowerPoint PPT presentation

Number of Views:58
Avg rating:3.0/5.0
Slides: 49
Provided by: lyncbe
Category:

less

Write a Comment
User Comments (0)
Transcript and Presenter's Notes

Title: Survey and Regulatory Update


1
  • Survey and Regulatory Update
  • October 6, 2008
  • Jill Snow, Sr. VP, Clinical Services
  • SavaSeniorCare
  • Lyn Bentley, Dir. Regulatory Services
  • American Health Care Association

2
Topics Covered Today
  • Survey Trends
  • CMS 2008 Nursing Home Action Plan
  • Five Star
  • Special Focus Facilities
  • Enforcement
  • Surveyor Guidance Revisions
  • Interpretive Guidelines
  • F325, F371
  • F323 Rewind!

3
Survey StatisticsTop 10 Health Survey TagsJune
2007 OSCAR Data
  • F371- Sanitary Conditions
  • F309 Highest Practicable
  • Well Being
  • F281 Professional
  • Standards
  • F323 Accidents
  • F324 - Supervision
  • F253 Housekeeping
  • Maintenance
  • F279 Care Plans
  • F315 Incontinence
  • F441 Infection Control
  • F314 Pressure Ulcers

4
Survey StatisticsTop 10 Health Survey TagsJune
2008 OSCAR Data
  • F253 Housekeeping and maintenance
  • F314 Pressure ulcers
  • F329 Unnecessary medications
  • F315 Catheterization
  • F441 Infection control
  • F323 Accidents/ hazards
  • F371 Sanitary Conditions
  • F309 Highest Practicable Well-Being
  • F281 Professional standards
  • F279 Comprehensive Care Plan

5
Survey StatisticsLife Safety Survey TagsJune
2007 OSCAR Data
  • K18 Construction of Doors
  • K29 Hazardous areas separate by Construction
  • K62 Sprinkler System Maintenance
  • K147 Emergency Plan
  • K38 Exits Accessible
  • K25 Smoke Partition Construction
  • K56 Sprinkler System of Approved Type
  • K50 Fire Drills
  • K144 Generators
  • K67 Ventilating Equipment

6
Survey StatisticsLife Safety Survey TagsJune
2008 OSCAR Data
  • K25 Smoke Partition Construction
  • K50 Fire Drills
  • K56 Sprinkler System of Approved Type
  • K144 Generators
  • K76 Medical Gas Systems
  • K18 Construction of Doors
  • K29 Hazardous areas separate by Construction
  • K62 Sprinkler System Maintenance
  • K147 Emergency Plan
  • K38 Exits Accessible

7
(No Transcript)
8
(No Transcript)
9
(No Transcript)
10
(No Transcript)
11
(No Transcript)
12
CMS 2008 Nursing Home Action Plan
  • Consumer Awareness and Assistance
  • Survey, Standards, and Enforcement Processes
  • Quality Improvement
  • Quality Through Partnerships
  • Value-Based Purchasing

13
Consumer Awareness and Assistance
  • Improve staffing data on CMS Web site
  • use payroll database extract?
  • Develop staffing quality measure (phase 2)
  • Develop immunization measures for public
    reporting

14
Survey, Standards, and Enforcement Processes
  • Background Check Pilot Preventing Abuse and
    Neglect
  • issue final national evaluation study summer 2008
  • Improving fire safety
  • better protection
  • better information
  • better monitoring
  • better enforcement

15
Survey, Standards, and Enforcement Processes
  • Interpretive guidance to surveyors
  • Refinement of state performance standards
  • Frequency Quality of Surveys Enforcement and
    Remedy Value
  • Establish escrow accounts for civil monetary
    penalties

16
Survey, Standards, and Enforcement Processes
  • Monitor civil monetary penalty amounts
  • Update nurse aide training curriculum
  • final report with policy options summer 2008

17
Quality Improvement
  • Development and validation of MDS 3.0
  • Data Assessment and Verification Contract (DAVE)
    2
  • STRIVE time study
  • publish final rule for SNF PPS

18
Quality Improvement
  • Expand Collaborative Focus Facility (CFF) Project
  • Culture change

19
Quality Approaches Through Partnerships
  • Communicating with other stakeholders
  • Advancing Excellence in Americas Nursing Homes
    Campaign
  • Emergency preparedness

20
Quality Approaches Through Partnerships
  • Long-term care task force
  • internal to CMS
  • Long-term care rebalancing

21
Value-Based Purchasing
  • Design nursing home value-based purchasing
    demonstration
  • Post-acute care instrument development and
    demonstration

22
Five Star Quality Program
  • CMS is presenting this program as an improvement
    to Nursing Home Compare
  • Rating system will include three components
  • Survey Results
  • Staffing
  • Quality Measures

23
Five Star, cont.Quality Measures
  • Subset of current NH Compare
  • ADL change
  • Mobility change
  • Long-stay prevalence measures
  • Pressure ulcers
  • Physical restraints
  • UTIs
  • Long-term catheters
  • Pain
  • Short-stay prevalence measures
  • Delirium
  • Pain
  • Pressure ulcers

24
Five Star, cont.
  • Topic Expert Panel includes primarily
    researchers, one provider representative
  • Abt is meeting with the panel for their ideas
    about development of Five Star
  • Abt is developing the weighting formula will
    be complete in Oct. 2008
  • First phase of Five Star will be live on CMS
    Web site in Dec. 2008

25
Five Star, cont.
  • Second phase of Five Star may include posting
    additional information
  • Patient/family satisfaction scores
  • Add new quality measures
  • Include specific characteristics of nursing homes
    (e.g., specialty units languages spoken private
    rooms)
  • Staffing data collected from payroll sources

26
Special Focus Facilities
  • Feb. 2008 CMS posted list of Special Focus
    Facilities to its Web site
  • List is updated about once a month
  • Categories
  • Newly added
  • Have not improved
  • Have shown improvement
  • Recently graduated
  • No longer certified

27
SFFs, cont.
  • If facility has been purchased, old name is shown
    in parentheses
  • Names of graduated and terminated facilities will
    remain on the CMS Web site for six months
  • Link to SFF list from Nursing Home Compare should
    be removed when a facility graduates

28
SFFs, cont.
  • In 9th Scope of Work for Quality Improvement
    Organizations, they must provide technical
    assistance to SFF each year of next 3 years of
    contract
  • State survey agency identifies potential SFFs and
    QIO contacts one
  • If facility, refuses, QIO contacts next SFF
    identified

29
Enforcement
  • Concerns raised by providers in Regions IV and V
    related to Immediate Jeopardy citations
  • AHCA contracted with PointRight to research
    citations in Regions IV and V
  • Information given to CMS
  • Status

30
Surveyor Guidance Revisions Update
  • F371 - Safe Food Handling- Mid 2008
  • F325 - Nutritional Parameters - Mid 2008
  • F309 Guidance for Pain Management 2008 or
    early 2009
  • F441 - Infection Control Fall 2009
  • F223 through F226 Abuse sometime in the
    future
  • F309 Guidance for End-of-Life sometime in the
    future

31
Key Policy Interpretations by CMS in 2008
  • Surveying facilities receiving food prepared by
    off-site kitchens
  • State Selection of Special Focus Facilities for
    technical assistance by QIOs
  • Use of Interpretive Guidelines

32
Structure of Interpretive Guidelines
  • Regulatory Text and F-Tag
  • Intent
  • Definitions
  • Overview
  • Endnotes (references)
  • Investigative Protocol
  • Decision Making compliance vs. non-compliance
  • Additional requirements (other F-Tags to
    consider)
  • Deficiency categorization (F-Tag, scope
    severity)

33
1/18/08 SC LetterUse of Interpretive Guidelines
  • What they are not
  • A requirement
  • A standard of practice
  • Lack of use is not deficient practice
  • A deficiency demonstrates how the facility fails
    to comply with the regulatory requirement not how
    it fails to comply with interpretation of the
    requirements.

34
1/18/08 SC LetterUse of Interpretive Guidelines
  • What they are
  • Authoritative (reliable) interpretation of
    regulatory language
  • Serve as guidelines
  • Specify survey protocols such as investigative,
    definitions of regulatory terms, and interview
    probes
  • Facilitates surveyors consistent regulatory
    interpretation, and
  • Determination of seriousness and scope of
    deficiencies.

35
1/18/08 SC LetterUse of Interpretive Guidelines
  • What they are (contd)
  • Accepted standards of practice
  • May reflect best and/or evidence-based practice
  • Educational tools for surveyors
  • Can be used to evaluate facility specific systems.

36
Common Themes of the Interpretive Guidelines
  • Systemic approach
  • Process oriented approach to resident care and
    facility operation
  • Evidence-based practices for clinical management
    areas
  • Resident approach
  • Care plans interdisciplinary and individualized
  • Quality Assessment and Assurance component
  • Staff knowledge vs. leadership knowledge

37
F325 Nutrition
  • Intent
  • Provide nutritional care and services to each
    resident, consistent with the residents
    comprehensive assessment
  • Recognize, evaluate and address the needs of
    every resident and
  • Provide therapeutic diet that takes into account
    the residents clinical condition and preferences.

38
F325 Nutrition
  • Merged F325 and F326
  • Assessment
  • Analysis
  • Interdisciplinary
  • Care Plan emphasis
  • Monitoring
  • No Level I

39
F371 Sanitary Conditions
  • Intent
  • Food for resident consumption obtained from
    approved sources
  • Proper sanitation practices and food handling
    practices to prevent the outbreak of food borne
    illness and
  • Begins when food is received from the vendor and
    continues throughout the facilitys food handling
    processes.

40
F371 Sanitary Conditions
  • Merged F370 and F371
  • Emphasis is on process to maintain sanitary
    conditions as much as the sanitary conditions
    itself looking for systemic approach
  • Knowledge
  • Staff that handle food (kitchen, nursing, FA,
    etc.)
  • Identify and prevent food hazards
  • 3 Categories of contaminants

41
F323 Rewind
  • Combination of F323 and F324
  • Intent
  • Resident environment remains as free of accident
    hazards as possible
  • Residents received adequate supervision and
    assistive devices to prevent accidents.

42
F323 Rewind
  • Examples of citations
  • Smoking
  • Elopement
  • Resident to Resident Altercation
  • Environmental hazards
  • Falls
  • WHY SUCH AN INCREASE?

43
Interpretive Guidance F323
  • Identify, Evaluate, Implement, Monitor
  • What systemic measures are in place to identify
    and evaluate risk for residents?
  • Fall management programs
  • Safety programs
  • Preventive maintenance programs
  • Behavior management programs

44
F323 Interpretive Guidance
  • Once identified, was the risk consistently
    addressed?
  • Example Facility cited under F323 for a
    defective resident lift device family had
    brought in the lift from home.
  • Problem Facility could not demonstrate a
    comprehensive preventive maintenance program that
    included having resident equipment inspected
    prior to use.

45
F323 Interpretive Guidance
  • Supervision
  • Adequate supervision is enhanced when the
    facility
  • Accurately assesses a resident and/or the
    resident environment
  • Determines that the supervision of the resident
    was necessary and provides supervision based on
    the individual residents assessed needs and
    risks identified in the environment
  • Examples Smoking, Resident to Resident

46
F323 Interpretive Guidance
  • Environment
  • Physical Environment
  • Hazards in the environment
  • Access to hazardous areas
  • Water temperatures
  • Devices and Equipment
  • Preventive maintenance
  • Maintenance alert
  • Safety Committees Essential

47
Common Themes of the Interpretive Guidelines
  • Systemic approach
  • Process oriented approach to resident care and
    facility operation
  • Evidenced based practices for clinical management
    areas
  • Resident approach
  • Care plans interdisciplinary and individualized
  • Quality Assessment and Assurance component
  • Staff knowledge vs. leadership knowledge

48
Questions
About PowerShow.com