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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 old saying you never get a second chance to make a first impression is sage advice for healthcare leaders. Nursing homes within the same geographical vicinity are competing with each other to attract talent, sometimes among a very limited pool of people. But nursing homes are also competing with other healthcare settings, and even with industries outside of healthcare. Depending on the market, working in a grocery store may pay more than being a CNA. Fresh approaches to attracting and retaining talent are necessary, but also provide exciting possibilities for healthcare leaders to engage a workforce devoted to caring for elders in their communities. To make a great first impression and improve the odds new employees will stay, nurse leaders should start by incorporating the principles of hospitality into the application and onboarding phases of the hiring process.
What is Hospitality?
Hospitality is the friendly and generous reception of visitors. Hospitality creates an experience for customers with the overall goal of attracting the customer to engage in the initial encounter and ultimately become a repeat customer. When done well, businesses are able to create loyalty to the brand, and customers share the positive experiences they’ve had with the brand in various social media outlets and return time and again.
Under the Patient-Driven Payment Model (PDPM), skilled nursing facilities (SNFs) need to have documentation in the medical record that will allow a medical reviewer, in the case of an additional documentation request (ADR), to determine that Medicare Part A skilled services were provided and that those services were reasonable and necessary, says Suzy Harvey, RN-BC, RAC-CT, managing consultant at BKD in Springfield, MO.
“While DNSs have a higher-level oversight role with regard to most aspects of Medicare Part A, you should have a more active role in ensuring that nursing documentation supports the skilled need. You or whoever you delegate this duty to needs to work with the MDS coordinator or Medicare consultant to ensure that nursing staff are documenting appropriately to support the skilled need.”
Directors of nursing services (DNSs) often take a largely hands-off approach to Medicare Part A coverage issues, says Suzy Harvey, RN-BC, RAC-CT, managing consultant at BKD in Springfield, MO. “In many facilities, DNSs more or less delegate the entire Medicare program to the MDS coordinator or the Medicare consultant. This ability to delegate is important because DNSs have such a demanding job. However, DNSs ultimately are responsible for all aspects of resident care. The MDS is a part of that, as are Part A skilled services.”
Consequently, DNSs still need to provide oversight—to be a member of the Medicare Part A team and to be aware of how well facility systems work by either auditing medical records or reviewing the results of delegated audits, suggests Harvey. “A DNS who just says, ‘The MDS coordinator handles that,’ could run into unexpected problems during medical review.”
“The implementation of the Patient-Driven Payment Model (PDPM) changed the payment system used for traditional Part A residents,” notes Harvey. “It did not change the coverage policies for skilled services.”
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.
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