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Historically, many providers have treated the MDS and the Resident Assessment Instrument (RAI) process as a silo of government-mandated busywork. That’s always been a problem because, since day 1, the primary purpose of the MDS has been to identify resident care problems that are addressed in an individualized care plan. However, the footprints of the MDS are now carved deep into multiple facets of facility life, including:
· The Medicare Part A Skilled Nursing Facility Prospective Payment System (SNF PPS);
· Some Medicare Advantage payment systems;
· Some Medicaid payment systems;
· The MDS-based quality measures (QMs) that are publicly reported on Nursing Home Compare and used in the Five Star Quality Rating System; and
· The MDS-based QMs that will be publicly reported under the Skilled Nursing Facility Quality Reporting Program (SNF QRP) beginning in October 2018 assuming ongoing data issues are resolved timely. Note: SNFs also must meet an MDS-based reporting threshold under the SNF QRP to avoid a SNF PPS payment penalty each fiscal year.
Last but not least, the new Long-term Care Survey Process (LTCSP) makes sure that surveyors have MDS-based clinical indicators to guide their investigations from the moment they walk in the door, according to the LTCSP Procedure Guide.
After the surveyors walk through the facility door, according to the Dining Observation checklist, they will observe the first full meal to be given after their entrance, in all dining areas. (If there are fewer surveyors than dining areas, they will observe those dining areas with the most dependent residents.) There are many, many things that surveyors will be looking for; these fall into four general categories:
1. Resident dignity—Is resident choice being honored?
2. Comfortableness of dining area—Is the dining area a comfortable temperature with appropriate lighting? Are residents positioned appropriately to eat effectively?
3. Food quality—Is food palatable?
4. Safe handling—Are serving conditions sanitary and safe?
As a leader in your facility, you have the power to underscore the importance of the staff’s role in affirming the dignity of all residents at all times, including at mealtime. The best way to prepare your staff for the items on the Dining Observation checklist is to cultivate awareness of what surveyors will be looking for, and the best way to do that is to lead by example and to train staff on proper dining room protocols. Here’s a review of what to look for before the surveyors do.
CMS updated these Long-term care survey process (LTCSP) FAQs on Feb. 6, 2018. Topics covered:
A. 483.10 Resident Rights; B. 483.12 Freedom from Abuse, Neglect, and Exploitation; C. 483.15 Admission, Transfer, and Discharge; D. 483.20 Resident Assessments; E. 483.21 Comprehensive Resident Centered Care Plans; F. 483.24 Quality of Life; G. 483.25 Quality of Care; H. 483.30 Physician Services; I. 483.35 Nursing Services; J. 483.40 Behavioral Health Services; K. 483.45 Pharmacy Services; L. 483.50 Laboratory, Radiology, and Other Diagnostic Services; M. 483.55 Dental Services; N. 483.60 Food and Nutrition Services; O. 483.65 Specialized Rehabilitative Services; P. 483.70 Administration, F838 Facility Assessment; Q. 483.75 Quality Assurance and Performance Improvement (QAPI); R. 483.80 Infection Control; S. 483.85 Compliance and Ethics Program; T. 483.90 Physical Environment; U. 483.95 Training Requirements; V. LTC Survey Process Training; W. LTC survey Process; and Z. General Questions.
Medicare beneficiaries, including elders and disabled persons, are being treated at inpatient and outpatient medical facilities for conditions that may be the result of abuse or neglect. The Elder Justice Act recognizes an older person's rights, including the right to be free of abuse, neglect, and exploitation. In addition, all 50 States have mandated reporter laws for the reporting of the potential abuse or neglect of elders and vulnerable persons. Prior OIG reviews have shown that there are problems with the quality of care and the reporting and investigation of potential abuse or neglect at group homes, nursing homes, and skilled nursing facilities. By analyzing the treating medical facilities' diagnoses, we will determine the prevalence of the potential abuse or neglect of Medicare beneficiaries. We will also determine whether the potential abuse or neglect occurred at a medical facility or at another location, such as the Medicare beneficiary's home.
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