You Are Here:Home/Resources/DNS Navigator/DNS Navigator Details
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.
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?’”
September marks my first full year as your chief staff executive. And what a year it was to step into this role! As I write this, we are less than two weeks from implementation of a new reimbursement model for skilled nursing facilities. PDPM’s impending arrival has resulted in unprecedented growth in our membership, conference attendance, and utilization of AAPACN’s education programs and tools.
To access this article, please login or sign up for a membership.