• In October 2018, the long-stay hospitalization measure will be posted on the Nursing Home Compare website as a long-stay quality measure. In the spring of 2019, this quality measure will be included in the Five Star Quality Rating System.  Additionally, in July 2018 we will update the other claims-based quality measures reported on the Nursing Home Compare website.
  
• To increase transparency, CMS will begin posting the number of hours worked by other staff (i.e., non-nursing) in July 2018. Facilities are required to submit hours for all other staff as listed in Table 1 of the PBJ Policy Manual. We will also distinguish between hours submitted for direct employees and contract staff. 
  
• In October 2019, CMS will resume posting the average number of citations per inspection for each state and nationally. CMS is monitoring outcomes of the new inspection process and plans to resume health inspection rating calculations (i.e., end the freeze) in the spring of 2019. CMS will communicate more details about this prior to its implementation.
  

Memo # 18-18-NH

Posting Date 2018-06-15

Fiscal Year 2018

Summary

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:

• When the current survey identifies Immediate Jeopardy (IJ) that does not result in serious injury, harm, impairment or death, the CMS Regional Offices may determine the most appropriate remedy; 
• We clarified that Past Noncompliance deficiencies (as described in §7510.1 of this chapter) are not included in the criteria for Immediate Imposition of Remedies; and, 
• For Special Focus Facilities (SFFs), S/S level “F” citations under tags F812, F813 or F814 are excluded from immediate imposition of remedies. 
• Revisions to Chapter 7 of the State Operations Manual (SOM) (Attachment): The Centers for Medicare & Medicaid Services (CMS) has revised guidance in Chapter 7 of the SOM related to the Immediate Imposition of Federal Remedies as noted in this memo and its attachment. Other sections of Chapter 7 have been revised to ensure conformity and consistency with these revisions.        

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: