The Long-Term Care (LTC) industry is just five months into phase 2 of the consolidated Medicare and Medicaid Requirements of Participation (RoP) for LTC Facilities. Phase 1 began on November 28, 2016, when the revisions were published in the final rule, followed by the roll out of phase 2 on November 28, 2017. Phase 3 is due to be set in motion on November 28, 2019. So how are we doing as an industry? As facility leaders, have we each read the 702 pages that are located in the Appendix PP of the State Operations Manual that captures the survey protocols and interpretive guidelines that serve to explain the intent of the regulations?
Those of us that have been in Long Term Care for years have memorized the Federal Citation numbers to use during facility licensing surveys, and now they have all changed. I live with my list of revised tags and the F-tag crosswalk readily available to refer to when I need to correlate compliance with facility action. Ultimately, the revisions to the rules were a complete update to the current best practices, safety and service delivery to those that reside in Long Term Care facilities. These revisions continue to support a resident’s voice and rights through the person-centered care perspective.
There are many requirements in Phase 2 that a facility must now have in place in order to be compliant.
Your QAPI Plan Should Be Ready Now
We had a year in phase 1 to continue our Quality Assurance and Process Improvement and develop a written QAPI plan that would be due in phase 2. The QAPI plan takes time to develop and should include all staff, residents and/or their responsible parties to determine improved processes of care.
The QAPI plan will need to be provided to your survey team during your annual licensing survey in written form. The process improvement plan (PIP) is not due until phase 3, but I am happy to see that facilities are embracing this part of the QAPI process now to continue to develop the quality service goals.
- Facility Assessment: A facility assessment is now due. The facility assessment takes into account facility acuity, vendor contracts, nurse competency, etc., and it takes time to review each area of care and support to complete.
- Discharge and Transfer Rules: The discharge and transfer rules have also been updated. Before a facility transfers or discharges a resident, a facility must notify the resident and the resident’s representative of the transfer or discharge. This notification must include the reasons for the move in writing in a language and manner they understand. The facility must also send a copy of the notice to a representative of the Office of the State Long-Term Care Ombudsman. This rule focuses on facility-initiated transfers and discharges. For example, when a facility decides to discharge a resident while the resident is still hospitalized or when a resident is temporarily transferred on an emergency basis to an acute care facility. Facilities need to be aware of the transfer and discharge needs, the timelines of those notices, and to whom and the format of those notices to be given.
- Antibiotic Stewardship: Other regulatory updates include antibiotic stewardship and the facility’s written policies and procedures surrounding the use of antibiotics as well as the prevention of infections during the resident’s stay. All of which will be required of the facility to write its infection control program.
- PRN Medications: There is a new 14-day time limit requirement for the use of PRN psychotropic and mood-altering drugs as well as a physician’s face-to-face assessment of the resident if these PRN medications are to be continued and the rationale for continue use. This also includes medications of these categories used in hospice.
- Emergency Preparedness: Emergencies that have affected our elderly population in Long-Term Care facilities, such as emergency power, fires, floods and other natural disasters, mean that a facility needs to have plans in place to cope. This involves making sure that the staff and residents are aware of evacuation programs and have table top trainings and actual disaster preparedness practice events held annually. These should all be driven by current policies and procedures.
So, What Does This Mean?
While this sounds like a lot, these are just a few examples. Then add the new survey process that began with phase 2. A facility has to find the time to work towards continual compliance practice and keep up with not only the day-to-day running of their individual facility but be on top of all of the compliance factors that are required in order to maintain their operating license. The gift is that there are many tools available, and Consonus Healthcare is available to help facilities navigate each of the components of the requirements of participation. Facilities need to understand that they are not alone in these processes and that we have a support system including contract pharmacists, therapists and consultants, whose job it is to work towards continual compliance and high quality resident centered care. We’ve gathered all the resources in one place. Our RoP toolkit is available to help a facility in their compliance success and give a facility the much-needed breathing space and time to get on with what they do best: taking care of the residents that they serve with the highest quality that they deserve.
Patti Garibaldi is the Director of Clinical Consulting Consonus Health and a clinical authority on all aspects of nursing in long-term care environments. Drawing on more than 30 years of experience, she is a high-demand speaker on topics ranging from medication management and MDS 3.0 to fall prevention, wound care, Quality Indicator Survey and Medicare PPS.