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Last month, we provided members with a list of the top ten federal deficiencies since January of 2019. As a reminder, the top ten deficiencies are:
F880 - Infection prevention and control
F689 - Free of accidents, hazards/supervision/devices
F812 - Food procurement/storage
F656 - Develop/implement comprehensive care plan
F684 - Quality of life
F761 - Label/storage of drugs and biologicals
F657 - Care plan timing and revision
F758 - Free from unnecessary psychotropic med/prn use
F677 - ADL care for dependent residents
F550 - Resident rights
(The citations above in red reflect the potential to cause substandard quality of care when a facility is cited at a scope and severity of F, H, I, J, K, or L level)
This month, we will take a deeper dive into the number three and four top citations and explore common reasons that facilities are struggling to meet these regulations.
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 twice in October 2019.
October 2019 Revisions
In October 2019, several changes were made to the Nursing Home Compare website and the Five-Star Quality Rating System. These changes affected the health inspection and quality measure domains. This section provides details on these changes.
Ratings changes for facilities that receive the abuse icon: To make it easier for consumers to identify facilities with instances of non-compliance related to abuse, starting in October 2019, CMS added an icon to highlight facilities that meet either of the following criteria:
Nursing homes that receive the abuse icon have their health inspection rating capped at a maximum of two stars. Due to the methodology used to calculate the overall rating, the best overall quality rating a facility that receives the abuse icon can have is four stars.
Removal of quality measures related to pain: CMS removed two quality measures (QMs) from the Nursing Home Compare website and the Five-Star Quality Rating System in October 2019. These measures are:
As a result of dropping these two measures, the cut-points for the long-stay, short-stay, and overall QM ratings changed. These changes were made to maintain, as close as possible, the same distribution of short-stay and long-stay QM ratings as were posted on Nursing Home Compare in July 2019.
CMS has established a Dementia Care Resources page to provide information that was previously housed at the National Nursing Home Quality Improvement Campaign. Additional resources are available through the QIO program.
· C. Infection Control Objectives for a Personnel Health Service
· D. Elements of a Personnel Health Service for Infection Control
· H. Emergency-Response Personnel
· J. The Americans With Disabilities Act
The updated recommendations are aimed at the leaders and staff of Occupational Health Services (OHS) and the administrators and leaders of healthcare organizations (HCO) and are intended to facilitate the provision of occupational infection prevention and control (IPC) services to HCP and prevent the spread of infections between HCP and others. Additional updates to the 1998 Guideline are underway and will be published in the future. Updates in Part I include:
· a broader range of elements necessary for providing occupational IPC services to HCP;
· applicability to the wider range of healthcare settings where patient care is now delivered, including hospital-based, long-term care, and outpatient settings such as ambulatory and home healthcare; and
· expanded guidance on policies and procedures for occupational IPC services and strategies for delivering occupational IPC services to HCP.
New topics include:
· administrative support and resource allocation for OHS by senior leaders and management,
· service oversight by OHS leadership, and
· use of performance measures to track occupational IPC services and guide quality improvement initiatives.
At the conclusion of the session, the participant will be able to accomplish the following:
The new interactive map below updates this information for years 2016 through 2018. Specifically, it displays details on nursing home complaint trends between 2016 and 2018 for each State, including the number of complaints received and the number of the most serious complaints that a State investigated late.
The U.S. Department of Health and Human Services published a new Guide for Clinicians on the Appropriate Dosage Reduction or Discontinuation of Long-Term Opioid Analgesics - PDF. Individual patients, as well as the health of the public, benefit when opioids are prescribed only when the benefit of using opioids outweighs the risks. But once a patient is on opioids for a prolonged duration, any abrupt change in the patient’s regimen may put the patient at risk of harm and should include a thorough, deliberative case review and discussion with the patient. The HHS Guide provides advice to clinicians who are contemplating or initiating a change in opioid dosage.
“Care must be a patient-centered experience. We need to treat people with compassion, and emphasize personalized care tailored to the specific circumstances and unique needs of each patient,” said Adm. Brett P. Giroir, M.D., assistant secretary for health. “This Guide provides more resources for clinicians to best help patients achieve the dual goals of effective pain management and reduction in the risk for addiction.”
Clinicians have a responsibility to coordinate patients’ pain treatment and opioid-related problems. In certain situations, a reduced opioid dosage may be indicated, in joint consultation with the care team and the patient. HHS does not recommend opioids be tapered rapidly or discontinued suddenly due to the significant risks of opioid withdrawal, unless there is a life-threatening issue confronting the individual patient.
Compiled from published guidelines and practices endorsed in the peer-reviewed literature, the Guide covers important issues to consider when changing a patient’s chronic pain therapy. It lists issues to consider prior to making a change, which include shared decision-making with the patient; issues to consider when initiating the change; and issues to consider as a patient’s dosage is being tapered, including the need to treat symptoms of opioid withdrawal and provide behavioral health support.
Nursing Home Quality Measure Changes
The following nursing home quality measures have been removed:
· Percentage of short-stay residents who report moderate to severe pain.
· Percentage of long-stay residents who report moderate to severe pain.
This change supports the federal initiative to reduce opioid utilization by seeking to prevent a potential scenario where the performance of a facility on the pain quality measures may inappropriately contribute to their decision to seek the administration of an opioid.
MDS 3.0 QM User’s Manual Version 12.1 Now Available
The MDS 3.0 QM User’s Manual Version 12.1 has been posted. The MDS 3.0 QM User’s Manual V12.1 contains detailed specifications for the MDS 3.0 quality measures. The MDS 3.0 QM User’s Manual V12.1 can be found in the Downloads section of this page and the MDS 3.0 QM User’s Manual V12.0 has been moved to the Quality Measures Archive page.
One file related to the MDS 3.0 QM User’s Manual has been posted:
1. MDS 3.0 QM User’s Manual V12.1 contains detailed specifications for the MDS 3.0 quality measures.
2. Quality Measure Identification Number by CMS Reporting Module Table V1.7 documents CMS quality measures calculated using MDS 3.0 data and reported in a CMS reporting module. A unique CMS identification number is specified for each QM.
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.
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