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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:
Once providers conceptually understand trauma-informed care, they often get stuck navigating what to do next. Steps that can help directors of nursing services (DNSs) and other members of the management team begin to operationalize trauma-informed care include the following:
Avoid a checklist mentality
“It sounds cliché, but trauma-informed care is a process, not a destination,” says Kathleen Weissberg, OTD, OTR/L, CMDCP, education director at Select Rehabilitation in Glenview, IL. “Every time I teach, I’m asked, ‘Where is my checklist? How can I make sure we are doing everything that we are supposed to do?’”
Effective this November 28, trauma-informed care will take center stage in the survey process for nursing facilities (NFs) and skilled nursing facilities (SNFs) as the Centers for Medicare & Medicaid Services (CMS) completes the final stage of rolling out the revised requirements for participation in Medicaid and Medicare. CMS will implement new trauma-informed care regulations under F699 (trauma-informed care), which is a quality-of-care F-tag; F659 (comprehensive care plans/qualified persons); F741 (sufficient/competent staff‐behavioral health needs); and F949 (behavioral health training).
These new or revised F-tags will come on top of two already implemented tags that address trauma—F742 (treatment/service for mental/psychosocial concerns) and F743 (no pattern of behavioral difficulties unless unavoidable)—giving surveyors a full suite of trauma-informed care tags to guide their investigations. Note: Read the Code of Federal Regulations citations that underpin the trauma-informed care requirements for each F-tag at the end of this article.
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