All Cause Harm Prevention in Nursing Homes Applying Strategies from the New CMS Change Package

Thursday, January 24, 2019, 3:00pm ET (1 hour) Recording Available.

One-third of SNF residents experience an adverse or temporary harm event, and the majority of those are preventable. As part of CMS’s focus on raising awareness of nursing home safety and to support safer nursing home care across the nation, CMS and the Quality Innovation Network National Coordinating Center released a new resource: a Change Package to prevent all cause harm in nursing homes. The Change Package is a compendium of successful practices of high-performing nursing homes, illustrating how they prevent harm while honoring each resident’s rights and preferences.

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:

Some residents require or request that their medication be crushed for oral administration. But not following CMS guidelines for crushing medications could result in a citation under §483.45(f)(2) F760 (Residents Are Free of Any Significant Medication Error). This citation could also occur in administering crushed medications via feeding tube. Facility leaders and the nurse administering the medications must first be sure that the particular medication can be crushed per manufacturer instructions. The Institute for Safe Medication Practices website can be a helpful resource in determining which medications should not be crushed.

CMS Guidance to State Survey Agencies on Verifying Correction of Deficiencies Needs To Be Improved To Help Ensure the Health and Safety of Nursing Home Residents (A-09-18-02000)

State survey agencies (State agencies) must verify that nursing homes corrected identified deficiencies, such as the failure to provide necessary care and services, before certifying whether the nursing homes are in substantial compliance with Federal participation requirements for Medicare and Medicaid.

MDS providers were notified by CMS on January 25th, that the reports in the 'MDS 3.0 Quality Measure Reports' category in the CASPER Reporting application would be unavailable while enhancements were being applied to the reports. These reports are now available and contain the following enhancements:

 

• Calculation updates/changes to short stay pressure ulcer measure, long stay pressure ulcer measure, and the long stay weight loss measure
• 'Hi-risk/Unstageable Pres Ulcer (L), N015.02' will display with 'Hi-risk Pres Ulcer (L), N015.01' measure results to see changes in calculations
• A new legend is present to direct users to the SNF QRP Quality Measure CASPER reports to view results for the SNF QRP Pressure Ulcer (S) Measure
• Updates made to columns/display for 508 compliance

• Adjustment of Civil Monetary Penalties (CMP) for Inflation: The Department of Health and Human Services (HHS) has published in the Federal Register on October 11, 2018, a final rule which adjusts for inflation CMP amounts authorized under the Social Security Act (See Adjustment of Civil Monetary Penalties for Inflation).

• New CMP Amounts: The final rule lists the new CMP amounts and ranges and are effective as of October 11, 2018.

• Selected Providers Highlighted: The CMPs under the authority of HHS affects multiple areas, but we are highlighting only on those CMPs assessed for Skilled Nursing Facilities (SNFs), Nursing Facilities (NFs), SNFs/NFs, Home Health Agencies (HHAs), and Clinical laboratories effective October 11, 2018.