Quality of Care/Life

The OIG’s Industry Segment-Specific Compliance Program Guidance (ISPG) for Nursing Facilities is a 59-page document that describes:

~  Risk areas for nursing facilities

~  Recommendations for mitigating those risks

~  Important info nursing facilities should consider in their compliance and quality programs

While the document states use of the word “should” is used to present voluntary, non-binding guidance, implementing the “should” items will be of great benefit to the facility.

The main Compliance Risk Areas are:

~  Quality of Care and Quality of Life

~  Medicare and Medicaid Billing Requirements

~  Federal Anti-Kickback Statute

~Other Risk Areas

Let’s dive into Quality of Care and Quality of Life. CMS Requirements for Participation for nursing facilities regarding standard of care and pertaining to Quality of Care and Quality of Life (QoC/QoL):

~Provide the care and services to achieve/maintain the highest standards of physical, mental, psychosocial well-being of each resident in accordance with standards of practice

~Provide the care in a place and a way that will promote or maintain each resident’s quality of life

~Have a Quality Assurance and Performance Improvement program that focuses on outcomes of care and quality of life

In other words: Give great care to each individual resident in a way that meets the individual needs and improves or maintains their quality of life.

The primary factor in meeting QoC/QoL is Staffing. Specifically, in the ISPG:

~Staffing Levels, Shortages, and Competencies

Do you have enough staff with the necessary skills and competencies to safely care for and meet the physical, mental, and psychosocial needs of the residents in your care?

CMS has requirements regarding the presence and availability of Registered Nurses; take it a step further…do your LPNs/LVNs and CNAs know what to do for the resident with a trach if the cannula falls out or the cuff is deflated? Or what education does your team need to care for a potential admission requiring specialized cares?

Staff recruitment seems to be an ongoing issue; what is your facility doing to retain the staff you have? If you have CNAs going to nursing school, can you develop a program allowing use of some of their newly acquired skills (with appropriate supervision)? Or a mentorship program to leadership or quality for some of your more seasoned nurses?

Honestly, this is just the tip of the iceberg for this topic.

How have you met competency challenges in your facility? What are your current struggles?

Next week, we’ll dive into Resident Care Plans and Resident Activities.

rachel@pathforgedconsulting.com