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Memo # 18-18-NH
Posting Date 2018-06-15
Fiscal Year 2018
This memo replaces the following Survey & Certification (S&C) Memos: 16-31-NH released July 22, 2016 and revised on July 29, 2016, and S&C: 18-01-NH, released in draft on October 27, 2017. The October 2017 memo solicited comments on a proposed directive requiring, for certain situations, immediate imposition of federal remedies on Medicare and Medicaid participating skilled nursing facilities. After reviewing comments, CMS is issuing a final version of the directive. Substantive revisions to the prior Immediate Imposition of Federal Remedies guidance include:
Since the new Long-Term Care Survey Process (LTCSP) launched on November 28, 2017, 702 citations have been given for F686 (Skin Integrity). 22% of those tags are a G scope or above. Many of the citations are for:
· Failure to provide care to treat and/or prevent worsening pressure ulcers
· Failure to prevent facility-acquired pressure ulcers
· Failure to develop and/or follow the care plan
· Failure to ensure accurate assessment, obtain treatment orders, or communicate with other professional staff
· Failure to prevent infection of wounds
Widespread pressure ulcer issues are no surprise when facilities don’t have proper protocols in place for prevention, early identification, and treatment, according to Wendy DeCarvalho, MS, BSN, RN, DNS-CT, Director of Nursing for Scotia Village in North Carolina. As a DNS and clinical nurse consultant in long-term care facilities nationwide, DeCarvalho has worked to improve Quality Measures, including those for pressure ulcer rates. “If the staff doesn’t have protocols in place, pressure ulcers often go unchecked, untracked, and untreated,” she says. She recommends the following best practices.
CMS created the Five-Star (5 Star) Quality Rating System to help consumers, their families, and caregivers compare nursing homes more easily. The Five-Star Quality Rating System Technical Users' Guide provides in-depth descriptions of the ratings and the methods used to calculate them. Updated May 2018.
F700 (Bedrails) is one of 17 discrete F-Tags now included under Section 483.25, Quality of Care, in Title 42 of the Code of Federal Regulations. These tags are among the indicators of substandard quality of care, meaning even a single deficiency with a scope/severity level of F, H, I, J, K, or L could potentially trigger an extended survey. Some recent standard surveys under the new Long-term Care Survey Process (LTCSP) indicate that providers may want to review their compliance in this area.
The new F700 tag has new corresponding interpretive guidance in Appendix PP of the State Operations Manual. The Key Elements for Noncompliance for F700 are as follows:
NOTE: CMS updated this file on May 15, 2018.
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