Not surprisingly, professional societies and long-term/post-acute (LTPAC) practitioners are very intent on analyzing and understanding what it happening with the revised nursing home survey process that went into effect last year. Early this month, Karen Tritz, Director, Division of Nursing Homes, Survey and Certification Group at CMS, shared some statistics and observations with members of the American Society of Consultant Pharmacists at the organization’s annual meeting. She observed that while the new process presented some challenges, it was less of a paradigm shift for facilities and practitioners that are adept at using computers to collect and share data.
The latest iteration of the federal Long-Term Care Survey Process began Nov. 28, 2017, with a focus on making sure that residents’ needs are met, they are kept safe, and they can attain or maintain their highest possible level of well-being. Tritz said that CMS listened to what providers, practitioners, and other had to say about the survey process and attempted to include best practices and opportunities for improvement, quality of life/care issues, and issues of concern such as antibiotic stewardship in the revised process.
Survey Results:
Looking back over the first year of the revised survey process, Tritz said that it didn’t really have much impact on the top deficiencies cited. Infection prevention (F880) and food procurement—storage (F812) remain at the top of the list. However, while the third most cited deficiency in FY 2017 involved accident & supervision (F689), in the new process comprehensive care plan (F656) was third. Some other changes worth noting:
- CMS is seeing double the number of investigations under the new process.
- The process has resulted in a slightly higher number of deficiencies.
- The survey team size has gone up slightly, and they are spending more time onsite. This is partly because surveyors are still learning the new process, said Tritz
- In FY 2018, there were 1,848 citations for tag F0758, Freedom from Unnecessary Psychotic Medications/PRN; 2,233 for Label/Store Drugs and Biologicals (F0761); and 1,272 for Pharmacy Services (F0755), “We’re continuing to see psychotropics without appropriate indications and/or monitoring,” Tritz said.
The Free Technology that Makes It Easier to Collect, Analyze, and Share Data
Under the revised survey process, surveyors conduct signification off-site preparation, and this requires facilities to have accurate, up-to-date, complete data. More than ever, this calls for coordination between team members. Moving forward, innovative technology as the CareTeam Platform (a freemium application) will make it easier to collect, analyze, and share date. The clinical documentation and messaging app will make surveys smoother and will help promote successful Quality Improvement projects and other efforts. With this platform, the entire care team can send messages, stay informed and manage patient care. They can attach and share labs, x-rays, discharge notes, pharmacy and therapy documents, and more. Not only will CareTeam help facilities provide information surveyors need; having this real-time information that can be accessed and shared easily can help prevent rehospitalizations, identify at-risk patients, view and analyze frailty scores, track quality measure performance, and compare physician and facility performance. To view a recorded demo, visit: http://info.gehrimed.com/careteam/demo
Having strong data collection systems in place, as well as effective ways to share data, now will make it easier and more productive as facilities and practitioners face Phase 3 of the Final Rule on Medicare and Medicaid Programs: Reform of Requirements for Long-Term Care Facilities, which is set to go into effect on November 28, 2019. Tritz urged her audience to start preparing for components of this phase, including the requirement for facilities to have a specialize infection preventionist. She noted that CMS is developing an infection prevention course that will be available on the U.S. Centers for Disease Control & Prevention (CDC) website. This program likely will be available in the Spring of 2019 and open to the public, she said. This is important, she noted, as many organizations seem to be struggling with antibiotic stewardship. “It’s an area we are continuing to track,” she said.
CMS has been collecting and reviewing feedback and comments about the revised survey process, and they are looking at ways to reduce the documentation, paperwork, and other issues that practitioners and providers say create added burdens. Tritz said. She observed, “We have been collecting comments and planning to publish burden reduction regulations.” She didn’t offer any specifics of what might be in these regs, but noted, “They’re currently working their way through the process.”
To make the whole process “as transparent as possible,” Tritz noted that CMS will unfreeze the Health Inspection Five-Star Ratings. The health inspection star ratings for recertification surveys and complaint investigations conducted on or after November 28, 2017, were frozen in 2018. Tritz said that CMS will release guidance and how and when this will happen shortly.
For more information, visit: http://info.gehrimed.com/careteam/demo