Risk Management

In a SNF, there are a lot of moving pieces, a lot to manage, and a lot can go wrong. Mitigating the risk of adverse events is a daily task. From care systems review and root cause analysis to anticipatory management, the resources below are designed to help you do just that. Protect your staff and residents now before you have to pick up the pieces after the fact. 

  • SNF QRP Comorbidity HCC Groups ICD-10 Codes Updated (7/20)

    By CMS - July 06, 2020

    These charts provide an update to the Comorbidity HCC groups used for the SNF QRP as covariates for the Change in Self-Care score, Change in Mobility score, Discharge Self-Care sore, and Discharge Mobility score.

    They appear to be an update/crosswalk to the ICD-10 codes listed in table A-5 of the SNF QRP Measure Calculations and Reporting User’s Manual.

    It's worth noting that, in the user guide, there are only 24 HCC Groups, but this updated crosswalk lists 190 groups.

    Read more
  • COVID-19 Testing: CDC Says Repeated Point Prevalence Surveys Can ID Asymptomatic Cases in SNFs (7/20)

    By CDC - July 01, 2020

    Initial and Repeated Point Prevalence Surveys to Inform SARS-CoV-2 Infection Prevention in 26 Skilled Nursing Facilities — Detroit, Michigan, March–May 2020

    Early Release / July 1, 2020 / 69

    Guillermo V. Sanchez, MSHS, MPH1; Caitlin Biedron, MD1; Lauren R. Fink, MPH2; Kelly M. Hatfield, MSPH1; Jordan Micah F. Polistico, MD3,4; Monica P. Meyer, MS, MPH3,4; Rebecca S. Noe, MN, MPH1; Casey E. Copen, PhD1; Amanda K. Lyons, MS1; Gonzalo Gonzalez, DNP2; Keith Kiama2; Mark Lebednick2; Bonnie K. Czander2; Amen Agbonze2; Aimee R. Surma, MS2; Avnish Sandhu, DO3,4; Valerie H. Mika, MS4; Tyler Prentiss, MA5; John Zervos, JD5; Donia A. Dalal2; Amber M. Vasquez, MD1; Sujan C. Reddy, MD1; John Jernigan, MD1; Paul E. Kilgore, MD4; Marcus J. Zervos, MD4,5; Teena Chopra, MD3,4; Carla P. Bezold, ScD2; Najibah K. Rehman, MD2 (View author affiliations)

    View suggested citation

    Summary

    What is already known about this topic?

    Symptom-based screening in skilled nursing facilities (SNFs) is inadequate to detect SARS-CoV-2 transmission. Repeated point prevalence surveys (serial testing of all residents and health care personnel at a health care facility irrespective of symptoms) can identify asymptomatic cases during outbreaks.

    What is added by this report?

    Repeated point prevalence surveys at 26 Detroit SNFs identified an attack rate of 44%; within 21 days of diagnosis, 37% of infected patients were hospitalized and 24% died. Among 12 facilities participating in a second survey and receiving on-site infection prevention and control (IPC) support, the percentage of newly identified cases decreased from 35% to 18%.

    What are the implications for public health practice?

    Repeated point prevalence surveys in SNFs can identify asymptomatic COVID-19 cases, inform cohorting and IPC practices, and guide prioritization of health department resources.

    Read more
  • CDC 2020 On-Demand Video Schedule for Vaccination Series that Runs July 1 - October 14

    By CDC - July 01, 2020
    Pink Book Series

    CDC is offering a series of weekly one-hour web-on-demand videos that will provide an overview of vaccination principles, general best practices, immunization strategies, and specific information about vaccine-preventable diseases and the vaccines that prevent them. Each video will include updated information from recent Advisory Committee on Immunization Practices (ACIP) meetings and votes.

    Audience

    Immunization providers: Physicians, nurses, nurse practitioners, pharmacists, physician assistants, DoD paraprofessionals, medical students, state and local immunization programs, etc.

    Continuing Education

    Continuing education will be available for each event.

    2020 Videos

    This year, because of limited staff availability during the ongoing COVID-19 response, the series will be prerecorded rather than live events. There is no registration process to view the sessions. The link to each course can be accessed on/after the indicated date. Questions about the material presented can be submitted to nipinfo@cdc.gov.

    2020 Release Schedule

    2018 webinar schedule with presentation information

    Date

    Topic

    July 1

    Principles of Vaccination

    July 8

    General Best Practice Guidelines, Part 1

    July 15

    General Best Practice Guidelines, Part 2, and Vaccine Safety

    July 22

    Immunization Strategies

    July 29

    Vaccine Storage and Handling and Vaccine Administration

    August 5

    DTaP/Tdap

    August 12

    Rotavirus and Hepatitis A

    August 19

    Meningococcal Vaccines

    August 26

    Measles, Mumps, Rubella

    September 2

    Polio and Hib

    September 9

    Varicella and Zoster

    September 16

    Hepatitis B

    September 23

    HPV

    September 30

    Pneumococcal Vaccines

    October 14

    Influenza

     


    Read more
  • CMS COVID-19 Nursing Homes Best Practices Toolkit and New QIN-QIO Virtual Assistance UPDATED (7/20)

    By CMS - June 30, 2020

    New tool provides innovative solutions for states and facilities to protect our nation’s vulnerable nursing home residents during emergency

    CMS has released a new toolkit (updated 6/29/20) developed to aid nursing homes, Governors, states, departments of health, and other agencies who provide oversight and assistance to these facilities, with additional resources to aid in the fight against the coronavirus disease 2019 (COVID-19) pandemic within nursing homes. The toolkit builds upon previous actions taken by the Centers for Medicare & Medicaid Services (CMS), which provide a wide range of tools and guidance to states, healthcare providers and others during the public health emergency. The toolkit is comprised of best practices from a variety of front line health care providers, Governors’ COVID-19 task forces, associations and other organizations, and experts, and is intended to serve as a catalogue of resources dedicated to addressing the specific challenges facing nursing homes as they combat COVID-19.

    “The coronavirus presents a unique challenge for nursing homes. CMS is using every tool at our disposal to protect our nation’s most vulnerable citizens and aid the facilities that care for them. This toolkit will support state, local leaders and nursing homes in identifying best practices to protect our vulnerable elderly in nursing homes” said CMS Administrator Seema Verma.  

    The toolkit provides detailed resources and direction for quality improvement assistance and can help in the creation and implementation of strategies and interventions intended to manage and prevent the spread of COVID-19 within nursing homes. The toolkit outlines best practices for a variety of subjects ranging from infection control to workforce and staffing. It also provides contact information for organizations who stand ready to assist with the unique challenges posed by caring for individuals in long-term care settings. Each state was involved in the creation of this toolkit, resulting in a robust resource that may be leveraged by a variety of entities serving this vulnerable population.

    Additionally, CMS has contracted with 12 Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs) to work with providers, community partners, beneficiaries and caregivers on data-driven quality improvement initiatives designed to improve the quality of care for beneficiaries across the United States. The QIN-QIOs are reaching out to nursing homes across the country to provide virtual technical assistance for homes that have an opportunity for improvement based on an analysis of previous citations for infection control deficiencies using publicly available data found on Nursing Home Compare.

    Read more
  • COVID-19 Waivers: CMS Article Answers Q's About 3-Day Hospital Stay & Benefit Period Ending/Renewal (6/20)

    By CMS - June 29, 2020

    3-day inpatient qualifying hospital stay waiver

    Benefit period ending/renewal waiver

    New MLN Matters article reviews in detail which residents each waiver applies to, including some useful examples for the benefit period waiver. Also provides extensive billing instructions.

    Read more
  • Calendar Q2 2020 PBJ Staffing Data Due Aug. 14, 2020 and Five-Star/Nursing Home Compare Updates From CMS (6/20)

    By CMS - June 26, 2020

    Changes to Staffing Information and Quality Measures Posted on the Nursing Home Compare Website and Five Star Quality Rating System due to the COVID-19 Public Health Emergency

    Memo #QSO 20-34-NH

    Posting Date 2020-06-25

    Fiscal Year 2020

    Summary

    The Centers for Medicare & Medicaid Services (CMS) is committed to transparency about changes in publicly reported information on nursing homes during the COVID-19 public health emergency. Changes to the Nursing Home Compare Website and Five Star Quality Rating System:

    • Staffing Measures and Ratings Domain: On July 29, 2020, Staffing measures and star ratings will be held constant, and based on data submitted for Calendar Quarter 4 2019.

    o Also, CMS is ending the waiver of the requirement for nursing homes to submit staffing data through the Payroll-Based Journal System. Nursing homes must submit data for Calendar Quarter 2 by August 14, 2020.

    • Quality Measures: On July 29, 2020, quality measures based on a data collection period ending December 31, 2019 will be held constant.

    Read more
  • CMS FAQs Detail Recommendations for Allowing Nursing Home Visits (6/20)

    By CMS - June 25, 2020

    CMS has issued seven Frequently Asked Questions to supplement existing guidance about the rules for nursing home visitations during the COVID-19 pandemic, starting with No. 1:

    1. What steps should nursing homes take before reopening to visitors? 

    Nursing homes should continue to follow CMS and CDC guidance for preventing the transmission of COVID-19, and follow state and local direction. Because nursing home residents are especially vulnerable, CMS does not recommend reopening facilities to visitors (except for compassionate care situations) until phase three when: 

    • There have been no new, nursing home onset COVID-19 cases in the nursing home for 28 days (through phases one and two) 

    • The nursing home is not experiencing staff shortages 

    • The nursing home has adequate supplies of personal protective equipment and essential cleaning and disinfection supplies to care for residents 

    • The nursing home has adequate access to testing for COVID-19 

    • Referral hospital(s) have bed capacity on wards and intensive care units

    Read more
  • CDC Long-term Care COVID-19 Resources Updated (6/20)

    By CDC - June 22, 2020

    Preparing for COVID-19 in Nursing Homes

    Updated June 25, 2020

    Summary of Changes to the Guidance:

    • Tiered recommendations to address nursing homes in different phases of COVID-19 response
    • Added a recommendation to assign an individual to manage the facility’s infection control program
    • Added guidance about new requirements for nursing homes to report to the National Healthcare Safety Network (NHSN)
    • Added a recommendation to create a plan for testing residents and healthcare personnel for SARS-CoV-2

    Related Pages

    Read more
  • CMS QSO Memo: Enhanced Enforcement Actions Based on Nursing Home COVID-19 Data and Inspection Results (6/20)

    By CMS - June 02, 2020

    The Centers for Medicare & Medicaid Services (CMS) unveiled enhanced enforcement for nursing homes with violations of longstanding infection control practices. The enhanced and targeted accountability measures are based on early trends in the most recent data regarding incidence of COVID-19 in nursing homes, as well as data regarding the results of the agency’s targeted infection control inspections. CMS is increasing enforcement (e.g., civil money penalties (CMPs)) for facilities with persistent infection control violations, and imposing enforcement actions on lower level infection control deficiencies to ensure they are addressed with increased gravity.

    The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provided additional funding to CMS for necessary survey and certification work related to COVID-19, of which $80 million in new resources will be available for states to increase surveys. To ensure effective oversight is achieved, CMS will allocate the CARES Act funding based on performance-based metrics. States that have not completed 100 percent of focused infection control surveys of their nursing home by July 31, 2020 will be required to submit a corrective action plan to their CMS location outlining the strategy for completion of these surveys within 30 days.  If, after the 30-day period, states have still not performed surveys in 100 percent of nursing homes, their CARES Act fiscal year 2021 allocation may be reduced by 10 percent.  Subsequent 30-day extensions could result in an additional 5 percent reduction. These funds would then be redistributed to those states that completed 100 percent of their focused infection control surveys by July 31.

    Utilizing the CARES Act funding, states will be required to perform on-site surveys of nursing homes with previous COVID-19 outbreaks and will be required to perform on-site surveys (within three to five days of identification) of any nursing home with new COVID-19 suspected and confirmed cases.

    To help nursing homes implement infection control best practices, CMS will provide technical assistance through Quality Improvement Organizations (QIOs). CMS and the Centers for Disease Control and Prevention (CDC) will continue to monitor the data it receives through the new nursing home COVID-19 surveillance system to identify nursing homes with outbreaks and work with Governor’s offices and states to keep nursing home residents safe.

    Since April 19, 2020, CMS has required nursing homes to inform, residents, their families, and representatives of COVID-19 cases in their facilities. For the first time, nursing homes are required to report COVID-19 cases and deaths directly to the CDC on an ongoing basis as the result of an unprecedented CMS regulatory requirement issued on May 1, 2020. The Trump Administration implemented the new reporting requirement to develop a robust federal disease surveillance system to quickly identify problem areas and inform future infection control actions. The reporting requirement applies to long-term care facilities only (also known as skilled nursing facilities and nursing facilities, and generally as nursing homes). By law, CMS regulates and oversees nursing homes, which are certified to provide Medicare and/or Medicaid skilled nursing facility services. Therefore, the data does not include COVID-19 data from assisted living facilities, which are not regulated at the federal level.

    As of May 24, 2020, about 12,500 nursing homes – approximately 80 percent of the 15,400 Medicare and Medicaid nursing homes – had reported the required data to the CDC. These facilities reported over 60,000 confirmed COVID-19 cases and almost 26,000 deaths. Of the nursing homes that reported data, approximately one in four facilities had at least one COVID-19 case, and approximately one in five facilities had at least one COVID-19 related death.  Early analysis shows that facilities with a one-star quality rating were more likely to have large numbers of COVID-19 cases than facilities with a five-star quality rating. CMS will take enforcement action against the nursing homes that have not reported data into the CDC as required under CMS participation requirements.

    CMS will post the underlying CDC-collected data on a link on Nursing Home Compare later this week, so the public can view general information of how COVID-19 has impacted nursing homes in a user-friendly format. The data will be broken down by state, number of residents and number of staff.  The data will be searchable by facility name and will be downloadable so researchers and other stakeholders can perform their own in-depth analysis.  CMS will update the data weekly. CMS will also post a link to the data on the home page of the Nursing Home Compare website so patients, residents, and families can easily find it. Nursing Home Compare is a valuable tool for patients, residents, and families to understand the quality of nursing homes and to support their healthcare decisions. Adding this information only increases its value and reinforces CMS’s commitment to transparency.

    CMS is ratcheting up penalties for noncompliance with infection control to help prevent backsliding, improve accountability, and ensure prompt compliance. Since February 2020 CMS has provided over 13 guidance documents and facts sheets pertaining to infection control and conducted weekly calls with nursing homes to share best practices from the field. The enhanced enforcement actions will increase penalties for nursing homes have had past infection control deficiencies.

    As part of CMS’s response to the COVID-19 pandemic, the agency prioritized the types of nursing home inspections that take place. On March 4, 2020 CMS prioritized inspections to allow inspectors to focus on the most serious health and safety threats like infectious diseases and abuse. On March 23, CMS suspended certain inspections to increase our focus on preventing the spread of COVID-19. Since March 4, CMS and its network of state-based inspectors have conducted over 8,300 surveys with the results of a total of 5,700 available today. There is currently wide variation in the number of focused infection control surveys of nursing homes performed by states, between 11.4 percent and 100 percent, with a national average of approximately 54.1 percent. CMS plans to post the results of the inspections later this week, on a monthly basis as they are completed.

    All of this information are being used to strengthen CMS enforcement action going forward, such that nursing homes are held accountable for resident care. Older Americans are particularly vulnerable to complications arising from the virus and nursing home residents have been uniquely affected. The Trump Administration is intensely focused on protecting this population, but it ultimately falls to the nursing homes themselves to ensure they provide care compliant with essential health and safety requirements.

    CMS is also providing additional support and technical assistance to low performing nursing homes through its QIOs. QIOs are organizations composed of health quality experts and clinicians that have experience in helping healthcare provider to improve the quality of care delivered to people with Medicare. CMS has now charged the QIOs to focus their efforts on providing education and training to all nursing homes in the country.  This will include weekly National Infection Control Training, which focuses on all aspects of infection control, prevention and management to help nursing homes prevent the transmission of COVID-19. 

    QIOs are also providing direct assistance to small and rural nursing homes and those serving vulnerable populations in areas where access to care is limited. The QIOs will help them understand and comply with CMS and CDC reporting requirements and, in some cases, they will provide on-site support to help nursing homes that have been identified as having the greatest needs in infection control. CMS will be working with Governors’ offices to direct QIOs to those nursing homes that have significant needs and have had outbreaks. QIOs will help these facilities create an action plan and implement specific steps to establish a strong infection control and surveillance program.

    Read more
  • COVID-19: CMS QSO Memo Details Nursing Home Reopening Recommendations for State and Local Officials (5/20)

    By CMS - May 19, 2020

    • Recommendations for State and Local Officials: CMS is providing recommendations to help determine the level of mitigation needed to prevent the transmission of COVID19 in nursing homes. The recommendations cover the following items:

    o Criteria for relaxing certain restrictions and mitigating the risk of resurgence: Factors to inform decisions for relaxing nursing home restrictions through a phased approach.

    o Visitation and Service Considerations: Considerations allowing visitation and services in each phase.

    o Restoration of Survey Activities: Recommendations for restarting certain surveys in each phase.

    Read more
  • OIG Targets Monitoring Psychotropic Drug Use in Nursing Homes (5/20)

    By OIG - May 18, 2020
    Previous OIG work found that elderly nursing home residents who were prescribed antipsychotics, a type of psychotropic drug, were at risk for harm. In response, the Centers for Medicare & Medicaid Services (CMS) took steps to address the risk of harm to nursing home residents. One such step was introducing a quality measure to track the rates of antipsychotic drug use in residents without an appropriate diagnosis. Recently, CMS and researchers expressed concerns that some nursing homes underreport antipsychotic drug use and may inaccurately report certain patient diagnoses in order to avoid CMS monitoring. Additionally, research on antipsychotic drug use has highlighted the need to closely monitor all psychotropic drug use to accurately oversee drug use in nursing homes. We will determine the extent to which there are inconsistencies, if any, between (1) Medicare claims data for residents prescribed psychotropic drugs compared to nursing home self-reported data on residents who received psychotropic drugs, and (2) Medicare claims data as it relates to the diagnoses that exclude residents from monitoring in the antipsychotic quality measure compared to nursing home self-reported data on resident diagnoses.
    Read more
  • CMS COVID-19 Stakeholder Engagement Calls – Week of 5/18/20

    By CMS - May 18, 2020

    CMS hosts varied recurring stakeholder engagement sessions to share information related to the agency’s response to COVID-19. These sessions are open to members of the healthcare community and are intended to provide updates, share best practices among peers, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.

    Call details are below. Conference lines are limited so we highly encourage you to join via audio webcast, either on your computer or smartphone web browser. You are welcome to share this invitation with your colleagues and professional networks. 

    Read more
  • OSHA Alert: COVID-19 Guidance for Nursing Home and LTC Facility Workers (5/20)

    By MX - May 18, 2020

    The Occupational Safety and Health Administration (OSHA) is committed to protecting the health and safety of America’s workers and workplaces during these unprecedented times. The agency will be issuing a series of alerts designed to keep workers safe. In a nursing home or long-term care facility, the following tips can help reduce the risk of exposure to the coronavirus.

    Read more
  • CMS QSO Memo updates F-tags and COVID-19 Focused Survey Tools to Include Reporting Requirements (5/20)

    By CMS - May 07, 2020
    Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes

    Memo # QSO-20-29-NH

    Posting Date 2020-05-06

    Fiscal Year 2020

     

    Summary

    • CMS is committed to taking critical steps to ensure America’s healthcare facilities are prepared to respond to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE).

    • On May 8, 2020, CMS will publish an interim final rule with comment period. • COVID-19 Reporting Requirements: CMS is requiring nursing homes to report COVID-19 facility data to the Centers for Disease Control and Prevention (CDC) and to residents, their representatives, and families of residents in facilities.

    • Enforcement: Failure to report in accordance with 42 CFR §483.80(g) can result in an enforcement action.

    • Updated Survey Tools: CMS has updated the COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes to reflect COVID-19 reporting requirements.

    • COVID-19 Tags: F884 and F885.

    • Transparency: CMS will begin posting data from the CDC National Healthcare Safety Network (NHSN) for viewing by facilities, stakeholders, or the general public. The COVID-19 public use file will be available on https://data.cms.gov/.

    Read more
  • National Healthcare Safety Network Long-term Care Facility COVID-19 Reporting Module Website (5/20)

    By CDC - May 05, 2020

    CDC’s NHSN provides healthcare facilities, such as long term care facilities (LTCF) with a customized system to track infections and prevention process measures in a systematic way.

    Tracking this information allows facilities to identify problems, improve care, and determine progress toward facility and national healthcare-associated infection goals.

    The NHSN Long-term Care Facility Component is supporting the nation’s COVID-19 response by introducing a new COVID-19 Module for Long Term Care Facilities. Facilities eligible to report into the COVID-19 Module include nursing homes/skilled nursing, long-term care for the developmentally disabled, and assisted living facilities.

    The COVID-19 Module for LTCFs consists of four pathways within NHSN’s Long-term Care Facility Component:

    • Resident Impact and Facility Capacity
    • Staff and Personnel Impact
    • Supplies and Personal Protective Equipment
    • Ventilator Capacity and Supplies

    The Module enables an assessment of the impact of COVID-19 in LTCFs through facility reported information, including: 1) counts of residents and facility personnel with suspected and laboratory positive COVID-19; 2) counts of suspected and laboratory positive COVID-19 related deaths among residents and facility personnel; 3) staffing shortages; 3) status of personal protective equipment (PPE) supplies; and 4) ventilator capacity and supplies for facilities with ventilator dependent units.  The Module does not collect staff or resident-level information.

    Participation in the COVID-19 Module for LTCFs requires facilities to be actively enrolled in NHSN. LTCFs that are currently enrolled in NHSN’s LTCF Component have immediate access to the new module and may begin reporting. If your facility previously enrolled, but is no longer able to gain access, contact NHSN user support at nhsn@cdc.gov for assistance. Please do not re-enroll a previously enrolled facility.

    LTCFs that are not enrolled in NHSN may gain access to the COVID-19 Module by completing the enrollment process outlined in the Enrollment section of this page. Upon completion, the facility will gain same-day access to NHSN.

    While daily reporting will provide the timeliest data for response purposes, retrospective reporting of prior day(s) is encouraged if daily reporting is not feasible. LTCF data submission options include manual entry, CSV file submitted by individual facilities or bulk CSV file upload for multiple facilities.  NHSN, in turn, will enable state and local health departments and the Centers for Medicare and Medicaid Services (CMS) to gain immediate access to the COVID-19 data for LTCFs in their jurisdictions. COVID-19 data submitted to NHSN also will be used by CDC’s emergency COVID-19 response and by the U.S. Department of Health and Human Services’ (HHS’) COVID-19 tracking system maintained in the Office of the Assistant Secretary of Preparedness and Response.

    Read more
1 of 8 Next