A few months ago, we provided members with a list of the top ten federal deficiencies since January of 2019. Since then, articles have delved deeper into the top four citations. This month, we will examine the number five and six top citations, explore common reasons that facilities struggle to meet these regulations, and discuss why surveyors cite them.

As a reminder, the top ten deficiencies are:

1. F880 - Infection prevention and control

2. F689 - Free of accidents, hazards/supervision/devices

3. F812 - Food procurement/storage

4. F656 - Develop/implement comprehensive care plan

5. F684 - Quality of care

6. F761 - Label/storage of drugs and biologicals

7. F657 - Care plan timing and revision

8. F758 - Free from unnecessary psychotropic med/prn use

9. F677 - ADL care for dependent residents

10. F550 - Resident rights

(The citations above in red have the potential to cause substandard quality of care when a facility is cited at a scope and severity of F, H, I, J, K, or L level)

The Centers for Medicare & Medicaid Services (CMS) most likely will specify education and training requirements for trauma-informed care under F741 (sufficient/competent staff‐behavioral health needs) and/or F949 (behavioral health training) in the upcoming revised Appendix PP, “Guidance to Surveyors for Long-term Care Facilities,” in the State Operations Manual—a revision that is now expected to be released in the second quarter of calendar year 2020, according to Quality, Safety, and Oversight (QSO) memo QSO-20-03-NH.

When they arrive, those requirements may not be too onerous because many staff members already should have skills that will translate across to trauma-informed care, such as knowing how to de-escalate and how to work with residents who have memory impairments, says Jill Schumann, MBA, president and CEO of LeadingAge Maryland in Baltimore and co-author of the Foundations of Trauma-Informed Care Toolkit and Implementing Trauma-Informed Care: A Guidebook.

Regardless of the exact requirements that CMS deems necessary, focusing on the following elements will help directors of nursing services (DNSs) and other members of the management team to implement effective trauma-informed care:

The Phase 3 requirements of participation for long-term care facilities went into effect on November 28—even those requirements that the Centers for Medicare & Medicaid Services (CMS) proposed delaying in the July 18 Requirements for Long-Term Care Facilities: Regulatory Provisions to Promote Efficiency and Transparency Proposed Rule, according to CMS officials at the December 12 Skilled Nursing Facility Long-term Care Open Door Forum.

Is the onboarding experience and orientation program in need of improvement in your nursing home? If so, you’re not alone; and the challenge is not unique to the healthcare industry. Only 12% of employees who completed the Gallup survey in 2017 said their employer did a good job onboarding them. According to surveys conducted by Digitate in 2018, only one in five employees would recommend their new employer to a friend after onboarding, and those who had a negative onboarding experience are twice as likely to look for new opportunities in the near future. With the demand high for a compassionate and competent workforce, and the current staffing crisis in post-acute care, investing in revitalizing the onboarding experience and orientation program in the nursing home could pay big dividends. The first article in the staffing solution series discussed ways to improve the onboarding experience using principles of hospitality. This article will build upon the first and discuss ways to improve the orientation program and encourage retention.

During the DNS’s daily rounds, he overhears two CNAs conversing about how two residents frequently argue. The DNS inquires and learns Ms. Smith and Mrs. Johnson, both residents living in the memory care neighborhood, had an argument over a purse the previous evening. Ms. Smith grabbed the purse out of Mrs. Johnson’s hand, hit her twice with the purse, and walked away. Later the same day, a CNA sees Ms. Smith holding Mrs. Johnson’s arm and warning her to stay away from her purse or she will hit her with it again. Mrs. Johnson shakes her head and asks Ms. Smith to help her find her dog. The CNA re-directs Ms. Smith’s attention and assists her to her room so she can watch her favorite TV show. Two days later, Mrs. Johnson’s husband reports a bruise on his wife’s arm and is demanding to know what happened to her. There is no documentation in the medical record or incident report on file for any of the resident to resident altercations observed by the CNAs, nor the bruise. The following day, a state surveyor enters the facility to investigate a hotline complaint of abuse and requests the medical records for Ms. Smith and Mrs. Johnson.

Ms. Smith and Mrs. Johnson probably remind readers of other residents currently or previously in their care. The scenario described is also likely familiar. However, the perception of and regulatory requirements related to resident to resident altercations have evolved, as has the expectation for each case to be investigated for potential abuse. F600 states “The resident has the right to be free from abuse, neglect, misappropriation of resident property, and exploitation as defined in this subpart.”