How have the new regulation and the new survey process changed the issues that surveyors are citing?
Dr. Andy Kramer
Even with the relatively small number of surveys that have been completed and reported in Nursing Home Compare using the new “Hybrid Survey” process (total of 2,436 surveys), the changes in deficiencies are dramatic. Although civil money penalties are temporarily suspended on many of the new regulations, and many system-wide regulations are yet to be implemented (Phase 3 beginning November 2019), providers can begin now to align their QAPI programs with the priorities of the new rule.
Looking at the most frequently cited deficiencies to date in the new survey offers some early indications of what is to come. At the top of the list, with citation on 39 percent of surveys since Phase 2 was implemented, is F880, Provide and Implement an Infection Prevention and Control Program.
The changes to this tag have been substantial, reflecting current infection control practices as articulated by the Centers for Disease Control for all health care settings. More will arise in Phase 3 with antibiotic stewardship and an infection prevention and control officer. Given the frailty of today’s nursing center residents, and the growing number of drug-resistant organisms, this must be a priority for all nursing centers.
‘Person-centered care, a major emphasis of the new rule, is being cited under several different tags.’
On 30 percent of the new surveys to date F656 was cited, Develop and Implement a Complete Care Plan that Meets all the Resident’s Needs. This is the starting point for person-centered care. However, also in the top 10 citations at 17 percent was F550, Honor Resident’s Rights re: Dignified Existence and Self-determination. F684 was also cited in 17 percent of surveys, Provide Appropriate Treatment and Care According to Orders, Resident’s Preferences and Goals. Not far behind, cited in about 11 percent of surveys was F584, Honor the Resident’s Right to a Safe, Clean, Comfortable, and Homelike Environment. In about 8 percent of surveys, still in the top 25 tags, was F578, Honor the Resident’s Right to Request, Refuse, and/or Discontinue Treatment, and to Formulate an Advance Directive.
Among the most frequently cited tags to date in the new survey are many clinical topics, including accident prevention; pressure ulcer prevention and care; and incontinence care, including catheter care and urinary tract infection prevention. Medication tags are also common, with frequent citations related to medication errors, unnecessary medications, proper storage of medications and pharmaceuticals, and monthly pharmacist review.
With the modest proportion of total new surveys completed to date, and the learning curve in early implementation, I am not suggesting you presume that these will necessarily be the emphasis of your first experience with the new survey. The message that I would like to convey is that the new regulations pertaining to both clinical and resident quality-of-life areas are causing a shift in the outcomes of the new survey. This shift reflects today’s expectations of health care. Some of these changes take time to permeate an organization, so I encourage you to start today to prepare for the future.