You Are Here:Home/Resources/DNS Navigator/DNS Navigator Details
Last month, we provided members with a list of the top ten federal deficiencies since January of 2019. As a reminder, the top ten deficiencies are:
F880 - Infection prevention and control
F689 - Free of accidents, hazards/supervision/devices
F812 - Food procurement/storage
F656 - Develop/implement comprehensive care plan
F684 - Quality of life
F761 - Label/storage of drugs and biologicals
F657 - Care plan timing and revision
F758 - Free from unnecessary psychotropic med/prn use
F677 - ADL care for dependent residents
F550 - Resident rights
(The citations above in red reflect 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)
This month, we will take a deeper dive into the number three and four top citations and explore common reasons that facilities are struggling to meet these regulations.
The survey process can be overwhelming. Surveyors arrive and begin evaluating whether the facility has met specific quality standards. Often, even the prospect of an impending survey leads to anxiety and fear for facility leaders and staff. Being aware of common citations and proactively putting plans in place to avoid those findings can help lessen the anxiety. Knowing the most-cited deficiencies and being survey ready at all times can help reduce the number of and lower the scope and severity of common citations.
Over the years, the top ten survey deficiencies have remained relatively constant, but the reasons that facilities receive a specific citation do vary across the country. Let’s look at the most-cited deficiencies across the nation since January 2019 and delve further into common reasons for the top two citations.
Every nursing facility must have resident care policies and procedures for respiratory care and services, including tracheostomy care and suctioning, to avoid a citation under §483.25(i) F695 Respiratory/Tracheostomy Care and Suctioning. The care policies must be developed with the medical director, the director of nursing, and when appropriate, a respiratory therapist. The respiratory care policies and procedures must be consistent with professional standards, be comprehensive and person-centered, and address each resident’s goals and preferences. The care policies must be developed prior to admitting any resident with respiratory care needs.
Many directors of nursing services (DNSs) have a hands-off approach when it comes to fee-for-service Medicare Part A and the MDS process, says Suzy Harvey, RN-BC, RAC-CT, managing consultant at BKD in Springfield, MO. “DNSs attend morning meetings and sometimes attend Medicare meetings, but they don’t really get involved because they count on their MDS staff to handle those processes.”
That approach works for the RUG-IV case-mix classification system, but when the Skilled Nursing Facility Prospective Payment System (SNF PPS) switches to the Patient-Driven Payment Model (PDPM) on Oct. 1, rehabilitation therapy will no longer drive Part A skilled care, says Harvey. “With PDPM focused on patient characteristics and skilled nursing services instead of therapy volume, nursing will become key to facility success in this new system, and as the supervisor of the nursing staff, the DNS will need to help lead the way.”
It’s important to note that working on PDPM isn’t just another task to add to the DNS’s plate, adds Harvey. “Getting paid appropriately is the focus of PDPM, but it ties back into quality of care. Much of what you will need to work on for PDPM will also benefit you on survey and your quality measures as well.”
Here are seven key steps a DNS can take to get out in front of PDPM:
Surveyors in the long-term care survey process (LTCSP) have begun to cite F684 (Quality of Care) with increasing frequency. As of July 2018, F684 is fifth most-common LTCSP tag. In comparison, it was the eighth most common in February, according to the July data available in QCOR, the Quality, Certification, and Oversight Reports site of the Centers for Medicare & Medicaid Services (CMS).
To access this article, please login or sign up for a membership.